Marc Gottridge, a partner at Hogan Lovells, writes that the "international concept of due process" requires only that foreign procedures not offend against "basic fairness" for a judgment reached by such a court to be recognized here. In only a handful of cases have courts applying the Recognition Act refused to recognize and enforce a foreign judgment on these grounds, illustrating how far from "fundamentally fair" a system must be for its judgments not to be accorded comity under the statute.
'Due Process' Exception to Recognition and Enforcement of Foreign Country Money Judgments
New York Law Journal
November 13, 2012
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