Appellant Berk-Cohen Associates, L.L.C. (“Berk-Cohen”) appeals the district court’s enforcement of an arbitration award on the grounds that the arbitrators acted with manifest disregard of the law. Assuming arguendo that the “manifest disregard of the law” standard is a valid basis for vacating an arbitration award for a dispute arising under a commercial contract, we agree with the district court that Berk-Cohen nonetheless failed to meet *970 this high standard of proof. We agree with the district court’s conclusion that the arbitration panel did not commit manifest error in ruling that Berk-Cohen should have mitigated the damages caused by the negligence of Orkin Exterminating Company, Inc. AFFIRMED.