The Recognition of U.S. Class Action Judgments Abroad: The Case of Latin America
Brooklyn Journal of International Law, Vol. 37, 2012
73 Pages Posted: 20 May 2012 Last revised: 1 Sep 2012
Date Written: June 4, 2012
Abstract
This article analyses the possibility that a foreign country would recognize and enforce a U.S. class action judgment (or court approved settlement). Although it centers its analysis in Latin American countries, it uses extensive European and Asian sources.
Due to peculiarities of the class action regimen of each country or to the traditional rules of recognition of foreign judgments, it concludes that no Latin American country would enforce and recognize a U.S. class action judgment or court approved settlement. The conclusions are applicable to all other countries.
Keywords: class actions, recognition, enforcement, international cooperation, Latin America
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