June 16, 2022
On June 13, 2022 the Supreme Court remedied a Circuit split with its unanimous Decision in ZF Automotive US, Inc. v. Luxshare, Ltd., (596 U. S. ____ (2022), citation pending), holding that 28 U.S.C. § 1782(a), which permits district courts to order discovery “for use in a proceeding in a foreign or international tribunal,” is limited to governmental or intergovernmental adjudicative tribunals and does not extend to private foreign arbitration tribunals.
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