PROBLEM: JUST ANOTHER STANDARD TERMS CASE

After negotiations without an agreement, Buyer in California sends Seller in New York an offer to buy described factory machinery. On the back of the offer a standard term provided that "all disputes arising out of or relating to this contract shall be arbitrated in Los Angeles under the Rules of the American Arbitration Association." Seller sends Buyer an acknowledgment of the order and then ships the goods by carrier. On the back of the acknowledgment, which Buyer received, there was a standard term that provided "all disputes relating to the conformity of the described goods to the contract shall be arbitrated in New York City under the rules of the International Chamber of Commerce." The goods were destroyed by fire in transit and a dispute arose over who had the risk of loss. Seller initiated arbitration against Buyer in New York to recover the price. Buyer sought an order staying the litigation pending arbitration and an order compelling arbitration in Los Angeles.

(1) How would this come out under current UCC 2-207?

(2) If Seller's place of business was in Toronto, Canada, how would this come out under CISG?