International Comity

Federal Court in Nevada Allows Ethiopia Bribery Claims to Move Forward

In a fascinating decision, the District Court for the District of Nevada (Judge Richard Boulware) recently allowed civil RICO claims to proceed against a Nevada resident based on bribery in Ethiopia, while dismissing claims against Ethiopian government entities under the Foreign Sovereign Immunities Act (FSIA). Fremichael Ghebreyesus v. Federal Democratic Republic of Ethiopia not only…

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Thoughts on the Petitioner’s Brief in Great Lakes

In a prior post, I surveyed the facts, procedural history, and potential significance of Great Lakes Insurance SE v. Raiders Retreat Realty Co., LLC, an upcoming Supreme Court case about the enforceability of choice-of-law clauses in maritime insurance contracts. In this post, I offer some thoughts on the brief filed by the petitioner, Great Lakes Insurance…

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Smagin‘s Surprises

Last week’s decision in Yegiazaryan v. Smagin was surprising in a number of respects, from the line-up of the Justices to the possible shift it signals in the presumption against extraterritoriality.

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Discovery and Immunity: LIV v. PGA

Photo by Edwin Compton on Unsplash

The U.S. legal battle between the PGA Tour (Tour) and the upstart rival LIV Golf continues to revolve around discovery. As regular TLB readers know, LIV Golf is a new professional golf tour that competes with the PGA, in part by luring PGA players to play in LIV tournaments. LIV is financed by the Public Investment…

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Rejecting Comity-Based Abstention in Human Rights Cases

Defendants in transnational human rights cases may seek dismissal on a great many bases—so many, in fact, that it can be hard to keep them all straight. One growing source of confusion is the argument that a case should be dismissed based on “comity.” The problem is that comity isn’t a single doctrine. But because…

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Another Court Rejects Chinese Data Privacy Law as a Bar to U.S. Discovery

A second U.S. decision has held that China’s Personal Information Protection Law (PIPL) did not bar a U.S. discovery request because of an exception in the law for statutory obligations. As previously reported on TLB, a federal court in California held last year that the PIPL’s exception for transfers “necessary to fulfill statutory duties and responsibilities or…

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Throwback Thursday: Blackmun’s Prescient Dissent in Aérospatiale

In Société Nationale Industrielle Aérospatiale v. U.S. District Court (1987), the Supreme Court held that U.S. courts need not treat the procedures set forth in the Hague Evidence Convention as the exclusive or even the primary means for managing discovery of evidence located abroad. Four justices dissented in part in a remarkably prescient opinion authored…

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A Primer on International Comity

The Supreme Court in Hilton v. Guyot (1895) famously defined international comity as “the recognition which one nation allows within its territory to the legislative, executive or judicial acts of another nation.” That definition is incomplete, however, as comity encompasses much more than the recognition of foreign acts. The Restatement (Fourth) of Foreign Relations Law…

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Throwback Thursday: American Banana and the Presumption Against Extraterritoriality

Today, it is “well established” that U.S. antitrust law applies extraterritorially to foreign conduct that causes substantial effects in the United States, but this was not always true. When the Supreme Court first addressed the geographic scope of the Sherman Act in 1909, it held that the act applied only to conduct in the United…

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How Do Federal Courts Treat Foreign Parallel Litigation?

The Supreme Court has not explained how federal judges should evaluate parallel litigation in foreign courts. If the same parties are litigating the same issues before a foreign tribunal, should the federal court stay its hand? Or should it proceed until one or the other of the cases results in a judgment? The traditional European…

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Ingrid (Wuerth) Brunk

Vanderbilt Law School
ingrid.wuerth@vanderbilt.eduEmail

William Dodge

George Washington University Law School
william.dodge@law.gwu.eduEmail

Maggie Gardner

Cornell Law School
mgardner@cornell.eduEmail

John F. Coyle

University of North Carolina School of Law
jfcoyle@email.unc.eduEmail

Zachary D. Clopton

Northwestern Pritzker School of Law
zclopton@law.northwestern.eduEmail

Gary Born

Wilmer Cutler Pickering Hale and Dorr LLP
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Robert Kry

MoloLamken LLP
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Luana Matoso

Max Planck Institute for Comparative and International Private Law
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Curtis A. Bradley

University of Chicago Law School
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Pamela K. Bookman

Fordham University School of Law
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Matthew Salavitch

Fordham Law School
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Hannah Buxbaum

Indiana University Maurer School of Law
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Paul B. Stephan

University of Virginia School of Law
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