In a Divergence From Other US Federal Circuits, The US Sixth Circuit Court of Appeals Rules That 28 U.S.C. § 1782 May Permit US Discovery for Use in Non-US Private Arbitrations

In contrast to its sister Circuits, a unanimous three-judge panel of the Sixth Circuit held that the word “tribunal” in the relevant clause of Section 1782 includes private arbitrations. This decision could make it easier for parties engaged in non-US arbitrations to obtain discovery from US entities, particularly those that fall within the Sixth Circuit’s jurisdictional reach.

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Consumer Contracts and the Restatement Project

The Restatement project presumes the exercise of nonpartisan judgment. Some criticisms of the draft are more political tracts than analytic critiques. Because the Draft does a good job analyzing and distilling the law, the real question in this debate is whether the ALI and the Restatement project as a whole can withstand efforts to use the tools and standards of retail politics to defeat the analytic approach of the Draft. To the extent such efforts succeed, the Restatement concept as a whole will fail.

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