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Case to Watch: Sahyouni v. Mamisch
I’m keeping my eye on Sahyouni v. Mamisch, Case No. C-372/16, a case in the EU Court of Justice. The husband and the wife, both Syrian nationals by birth, were married in an Islamic court in Homs, Syria in 1999. They moved to Germany, and both were German citizens. In 2013, the husband divorced the……
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Thoughts on The Chinese Decision On Recognizing a US Judgment
If you haven’t read Dr. Jie Huang’s important report on a Chinese court’s unprecedented recognition of a US commercial money judgment, read it now. This is a big deal. I have just a few comments on the development.
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Case of the Day: Louis Dreyfus Commodities Suisse v. Financial Software Systems
The case of the day is Louis Dreyfus Commodities Suisse SA v. Financial Software Systems, Inc. (3d Cir. 2017). FSS, a Pennsylvania corporation, licensed software to Dreyfus, a Swiss company, in 1996. In 2012, they amended the license agreement to include an exclusive choice of forum clause providing that disputes would be litigated in England.……
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Case of the Day: Banque de Tahiti v. Kurth
The case of the day is Banque de Tahiti v. Kurth (Haw. Ct. App. 2017). The Bank of Tahiti had a judgment against Filola Kurth, the representative of the estate of Thomas Kurth, from the Civil Court of First Instance of Papeete, the capital of French Polynesia. The Bank filed the judgment in Hawaii in……
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Case of the Day: Deutsche Bank v. Sebastian Holdings
The case of the day is Deutsche Bank AG v. Sebastian Holdings, Inc. (Conn. Ct. App. 2017). Sebastian Holdings was a Turks and Caicos company. Deutsche Bank sued Sebastian in England on a claim relating to trading losses Sebastian had incurred in connection with a trading account it had opened with Deutsche Bank. The English……