Cross-border Insolvency; Extra-territorial Effect; Jurisdiction; Applicable Law; Recognition and Enforcement of Foreign Bankruptcy Judgment.

跨国破产；域外效力；管辖权；法律适用；承认与执行外国破产判决。

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Judges in the U.S. will reject a foreign judgment achieved through a process not to their liking.

FORBES: Chevron Ecuador Plaintiffs Face Tough Sell In U.S.

The U.S. would normally be the most hospitable court system for enforcing a foreign judgment but Chevron has mounted simultaneous legal attacks in courts around the country to convince judges the Ecuadorean case is tainted by fraud.

FORBES: Chevron Says Plaintiffs Offered Ecuador Judge $500,000 For Verdict

Brown expressed some puzzlement that the plaintiffs had hinged their strategy on trying to convince an Ontario court to seize the assets of a Canadian corporation with few operations in the province, based on the fact that it is owned by a U.S. corporation with a foreign judgment against it.

FORBES: Chevron Plaintiffs Lose A Crucial Round In Battle To Enforce $18 Billion Judgment