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U.S. Courts Confirm Judgment Recognition Approach to Annulled Awards
24 July 2017
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Three recent judgments refusing to enforce annulled arbitral awards continue U.S. courts’ focus on the associated foreign court judgments.
Both the D.C. and Second Circuit courts granted comity to foreign courts’ annulment decisions, while the New York state appellate court denied comity to a foreign court’s recognition of an annulled award.
The New York state court even went one step further and enjoined a party from taking steps to enforce the annulled award abroad. This appears to be the first time that a New York court has restrained enforcement of an arbitral award abroad.
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