Category: Recognition and Enforcement

  • Case of the Day: Codemasters Group v. SouthPeak Interactive

    The case of the day is Codemasters Group Holdings Ltd. v. SouthPeak Interactive Corp. (E.D. Va. 2011). Codemasters, an English video game developer, had a video game distribution agreement with SouthPeak, a Delaware corporation doing business in Virginia. Codemasters’ claim was that SouthPeak, its distributor, had failed to pay invoices for games Codemasters had shipped……

  • Article of the Day: Jie Huang on Recognition of Judgments In Hong Kong

    In today’s article of the day, Conflicts Between Civil Law and Common Law in Judgment Recognition and Enforcement: When is the Finality Dispute Final?, 29 Wis. Int’l L. J. 70 (2011), Professor Jie Huang, of the Shanghai Institute of Foreign Trade’s School of Law, examines the difficulties involved in recognition and enforcement of Mainland Chinese……

  • Legislation of the Day: Ecuador To Refuse To Enforce Spanish Mortgages

    Nicolás Zambrana Tévar has posted at Conflict of Laws.net on an unusual and maybe ridiculous bill before the Ecuadoran parliament on the recognition and enforcement of foreign judgments. I’ve written before about the SPEECH Act, the new US statute that forbids recognition and enforcement of foreign judgments in defamation cases unless the foreign proceedings gave……

  • Case of the Day: Guessous v. Chrome Hearts, LLC

    The case of the day, Guessous v. Chrome Hearts, LLC (Cal. Ct. App. 2011), is another example of a party seeking recognition of a foreign judgment for defensive rather than offensive purposes, i.e., in order to defend against a claim in a US court on grounds of res judicata. In the mid-1990s, Chrome Hearts sued……

  • NML Capital Goes To Europe

    NML Capital, one of Argentina’s creditors, has been trying to collect on a US judgment for years. As we saw in NML Capital v. Banco Central (2d Cir. 2011), the case of the day from July 8, 2011, the Second Circuit held that the assets of the Argentine Central Bank on deposit with the Federal……