For example, a United States court held that the mere fact that the tribunal President and the
counsel of one of the parties both served on the same board of directors and were members of the same organization was insufficient to justify a refusal, where the party bringing the
challenge had provided no evidence that they had otherwise communicated with each other.889 A Hong Kong court has equally affirmed this high burden of proof, finding that the party
opposing enforcement had failed to prove its allegation that the tribunal's deliberations had been affected
by the alleged bias of one member.890