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Transatlantic litigation: service of US proceedings in the UK under the Hague Convention
Posted: 13/02/2025
In today’s global economic landscape, more and more US corporations are conducting business in foreign jurisdictions, and entering into contractual relationships with individuals and entities based abroad. Much of that business is conducted in the UK. In 2023, the US was the UK’s largest import and export partner for services and was......>>
Enforcing US judgments: when it doesn’t pay to multiply your award (Motorola v Hytera)
Posted: 28/01/2025
Claimants (plaintiffs) in US litigation are generally delighted when they are awarded multiple damages as additional or punitive compensation for the civil wrong they have suffered. However, trying to enforce a US judgment for multiple damages in the UK can lead to disastrous consequences, as a recent High Court judgment shows.
Transatlantic litigation: disclosure, discovery and the difference
Posted: 08/08/2024
An essential part of the litigation process, whether the case was initiated in the courts of England and Wales, or in the federal (and state) courts of the United States, is the formal process of exchanging information between the parties about the factual evidence that they intend to present at trial. Known as ‘disclosure’ in England and Wales......>>
Transatlantic litigation: a comparative analysis of privilege in the US and in England and Wales
Posted: 06/08/2024
Privilege is a fundamental right under both English and US law. It entitles a party (or its successor in title) to withhold evidence from production to third parties or a court. Some types of privilege protect communications between lawyers and their clients, the purpose being to allow parties to speak openly with their lawyer without fear that such......>>
Should I stay or should I go – when will the courts stay enforcement of a foreign judgment?
Posted: 30/07/2024
Recent judgments have shone a light on the English courts’ interpretation of the notoriously complex rules on enforcement of foreign judgments. In particular, the courts have considered the effect of an appeal pending in the foreign court, the defendant’s submission to the foreign court, and whether or not a foreign judgment can form......>>

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