1 Choice of Forum

1
Jurisdiction
(3) Recognition of Judgment?
(1) Choice of Forum
(2) Choice of Law
(4) Foreign Currency liability?
Hague Convention? Art 8
K b/n States Intl law, treaty
Hedge contract?
8) Arbitration Clause?
UN Convention on Recognition Enforcement of
Foreign Arbitral Awards Art. 2
1) Legislative/ Prescriptive Jurisdiction?
K b/n 2 private parties national law
Uniform Foreign Money Claims Act
K b/n private party foreign Gov Intl law
and/or law of foreign Gov
Restatement 3d 823 (most equitable)
3) Personal Jurisdiction?
2) Subject Matter Jurisdiction?
High deference to arbitration clauses
4) Long Arm Statute? Constitutional Analysis?
Uniform Foreign Money Recognition Act Art. 2
final? Art. 3 enforceable (Uniform Enforcement
Recognition Act) Art 4 Exceptions?
Diversity 1332
Fed Q? 1331
If arbitration no choice, look to law where
arbitration is in
7) Signatory to Hague Convention?
5)Specific Jurisdiction? Do Min Contacts Analysis
5)General Jurisdiction Helicopteros contacts
systematic continuous is office present Must
expect to be subject to suit suffer no
inconvenience
6) Forum Non Conveniens? Even if SMJ PJ dismiss
due to interest of fairness can dismiss if
theres another forum that can hear the case
(Piper)