The case of the day, In re Application of National Syndicate for Electric Energy (E.D. Va. 2014), is another in a recent group of unrelated cases indicating the limits of 28 U.S.C. § 1782, and in particular, the statute’s limitation to “foreign or international tribunals.” The National Syndicate for Electric Energy (SNEE) is a union of electrical workers in Cameroon. It was involved in a labor dispute with AES Corp., a US firm. In 2008, SNEE filed a complaint with a Ministry of Labor inspector seeking conciliation under the Cameroon Labor Code. Conciliation is a necessary prerequisite to arbitration. At the end of the conciliation, the labor inspector issues a report and refers the dispute to an arbitrator if the parties have not reached…

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