'Due Process' Exception to Recognition and Enforcement of Foreign Country Money Judgments

, New York Law Journal


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.

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