The English Court does not recognise judgments or orders of American Courts as a matter of comity. Instead, English Courts “regard the source of the territorial jurisdiction of the court of a foreign country to summon a defendant to appear before it as being his obligation for the time being to abide by its laws and accept the jurisdiction of its courts while present in its territory.” Adams v Cape [1990] Ch. 443.
33. In the leading modern case on enforcement of judgments at common law (which is how US judgments may be enforced in England), so described by Dicey, the Court of Appeal in Adams v Cape stated that “comity or reciprocity is an inadequate ground for enforcement in England of the judgment of a foreign court.” (Pages 455-56). The court also made clear that it supported the authority of a foreign court to summon a defendant before it and obligate that defendant to abide by its laws and jurisdiction while in that territory. (Page 519).

Steven