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US International Arbitration

A collection of the most recent US international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.

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  • Shenzhen Yunzhongge Technology Co. Ltd., v. Amazon.com Services LLC, No. 2:23-CV-01693-TL (W.D. Wash. Apr. 17, 2024)
    04/17/2024

    Court denied plaintiff’s motion to vacate an arbitration award under the FAA for liquidated damages in connection with plaintiff’s alleged violation of defendant’s online sales policies.  Court held that the arbitrator did not manifestly disregard the law, the award did not violate public policy, and the award was not a completely irrational interpretation of the underlying contract.  Court granted defendant’s cross-motion to confirm the award.

  • Huzhou Chuangtai Rongyuan Investment Management Partnership, v. Qin, No. 23-0747 (2d Cir. Apr. 10, 2024)
    04/10/2024

    Court of appeals affirmed district court judgment granting motion for summary judgment to confirm a CIETAC arbitration award under the New York Convention and denying a motion for reconsideration where petitioner was provided adequate notice of arbitration.

  • Lam v. Rise Huge Corporation Ltd., No. 22-CV-06094-TLT (N.D. Cal. Apr. 8, 2024)
    04/08/2024

    Court dismissed action to uphold international arbitration award under the New York Convention for lack of personal jurisdiction where a Hong Kong defendant’s only contact with California was a contract for a one time stock purchase with a California defendant.

  • Urangesellschaft MBH v. Nynco Trading Ltd, No. 23-CV-07713-DEH (S.D.N.Y. Apr. 5, 2024)
    04/05/2024

    Court granted motion to confirm ICC arbitration award rendered in Switzerland under the New York Convention, where respondent did not oppose the motion. Court awarded petitioner’s attorney’s fees and costs, and pre-judgment interest at a rate of nine percent, finding it was common practice within courts in the Second Circuit.

  • Wilson v. Carnival Corp., No. 23-10122 (11th Cir. Apr. 4, 2024)
    04/04/2024

    Court of Appeals affirmed district’s court decision to dismiss plaintiff’s motion to vacate arbitration award with its legal seat in Panama, finding under the Panama Convention that only courts with primary jurisdiction, the legal seat of the arbitration, can vacate an arbitral award.

  • Bua International Limited v. Domtec International LLC., No. 23-CV-00206-DCN (D. Idaho Apr. 1, 2024)
    04/01/2024

    Court denied petitioner’s request for attorneys’ fees and costs, finding that while the arbitrator ordered respondent to pay for petitioner’s costs of the arbitration, it did not award future costs such as attorneys’ fees incurred in confirming the award.

  • Seagen Inc. v. Daiichi Sankyo Co. Ltd., 22-CV-01613-JLR (W.D. Wash. Apr. 1, 2024)
    04/01/2024

    Court denied plaintiff’s petition to vacate and granted defendant’s cross-motion to confirm  arbitration award.  Court found arbitrator plausibly interpreted the parties’ agreement and did not disregard the applicable law, nor act irrationally, where the arbitrator explicitly addressed, but denied, plaintiff’s claims.

  • Deutsch Telekom AG v. Republic of India, No. 1:21-CV-01070-RJL (D.D.C. Mar. 27, 2024)
    03/27/2024

    Court granted petition to confirm a Swiss arbitral award, rejecting respondent’s forum non conveniens argument because the doctrine is unavailable in proceedings to confirm foreign arbitration awards in the D.C. Circuit. Court held it had jurisdiction under the arbitration exception to the Foreign Sovereign Immunities Act and rejected respondent’s argument that it was entitled to additional briefing on its merits defenses under the New York Convention.

  • Huzhou Chuangtai Rongyuan Investment Management Partnership v. Qin, No. 23-0747 (2d Cir. Mar. 20, 2024)
    03/20/2024

    Court of appeals affirmed district court’s confirmation of CIETAC arbitral award pursuant to the New York Convention, rejecting defendant’s argument that he was not provided adequate notice of the arbitration and was therefore unable to participate in the selection of arbitrators. Court of appeals concluded that plaintiff made sufficient efforts that were reasonably calculated to provide notice to defendant.

  • Employers’ Innovative Network, LLC v. Bridgeport Benefits, Inc., No. 18-CV-01082 (S.D.W. Va. Mar. 18, 2024)
    03/19/2024

    Court granted defendants’ joint motion to confirm and enforce arbitration award under the New York Convention, finding plaintiffs failed to prove that confirmation of the award would be contrary to public policy considering the arbitrator’s failure to disclose a potential conflict of interest. Court concluded that plaintiffs’ failure to challenge the arbitrator in Bermuda foreclosed their public policy defense and regardless, plaintiffs failed to conclusively offer proof of, or prejudice resulting from, the arbitrator’s perceived partiality.

  • Simplot India LLC v. Himalaya Food International LTD, No. 23-CV-01612-RK-TJB (D.N.J. Mar. 15, 2024)
    03/15/2024

    Court denied petitioners’ motion to confirm foreign arbitral award, holding there was no personal jurisdiction over respondent. Court found unpersuasive petitioners’ argument that a related domestic company was respondent’s alter ego; that respondent consented to general jurisdiction by registering to do business in New Jersey and accepting service by its designated agent; or that court may exercise quasi in rem jurisdiction over the related domestic company’s debts owed to respondent, because respondent lacked sufficient interest or control in the property.

  • Vamed Management und Service GMBH v. Gabonese Republic, No. 22-CV-03737-RJL (D.D.C. Mar. 13, 2024)
    03/13/2024

    Court granted motion for a default judgment and confirmation of the underlying arbitration award against respondent, where Gabon had not filed an appearance in the matter or otherwise participated in the confirmation proceedings.  Shearman & Sterling is counsel for Vamed Management und Service GMBH in connection with this case.

  • Metropolitan Municipality of Lima v. Rutas de Lima S.A.C., No. 20-CV-02155-ACR (D.D.C. Mar. 12, 2024)

    03/12/2024

    Court denied petition to vacate two arbitration awards and granted cross-motions to confirm them, where grounds for refusal or deferral of recognition or enforcement of the awards under the New York Convention were not met. Court noted that two independent tribunals had rejected claims of bribery related to an underlying infrastructure contract to build, improve, and maintain urban highways in Peru and declined to accept petitioner’s argument that denial of the bribery before the tribunal was fraudulent. Court also disagreed that the second arbitral tribunal committed misconduct in admitting some, but not the annexes, to a prosecutorial indictment it introduced after the close of evidence.

  • Cowin Technology Co., Ltd. v. Amazon.com Services LLC, No. 23-CV-03054-ALC (S.D.N.Y. Mar. 12, 2024)
    03/12/2024

    Court denied petition to vacate arbitral award and granted respondents’ cross-motion to confirm the award, where petitioner had not demonstrated that one of the seven exclusive grounds for refusal or deferral of recognition or enforcement of the award under Article V of the New York Convention applied.

  • Shenzhen Gooloo E-Commerce Co., Ltd. v. Pilot, Inc., No. 23-CV-00854-PAB-SBP (D. Colo. Mar. 8, 2024)
    03/08/2024

    Court granted motion to dismiss petition to vacate arbitration award and ordered that the arbitration award be confirmed, where petitioner did not sufficiently allege that the arbitration award was in manifest disregard of the law or that the arbitrator exceeded his authority under the terms of the arbitration agreement.

  • Valentino S.p.A. v. Mrinalini, Inc., No. 23-CV-02319-MKV (S.D.N.Y. Feb. 26, 2024)
    02/26/2024

    Court granted petition to confirm arbitration award, finding that respondent failed to prove grounds under Article V of the New York Convention to refuse or defer the recognition of the award.  Court denied petitioner’s request for attorneys’ fees, finding that respondent’s actions did not warrant that exceptional award but found petitioner’s expenses would be allowed to the extent that costs are available to the prevailing party.

  • Stonex Markets LLC v. Cooperativa de Caficultores del Suroeste de Antioquia, No. 23-CV-00513-JGLC-OTW (S.D.N.Y. Feb. 21, 2024)
    02/21/2024

    No. 23-CV-00513-JGLC-OTW (S.D.N.Y. Feb. 21, 2024)
    Court accepted magistrate judge’s report and recommendation to enter a motion for default judgment to confirm arbitration award finding the recommendation to be well reasoned and grounded in fact and law.

  • Telecom Business Solutions, LLC v. Terra Towers Corp., No. 22-CV-01761-LAK (S.D.N.Y. Feb. 20, 2024)
    02/20/2024

    Court granted motion for an anti-suit injunction against defendant where a foreign litigation would frustrate the arbitration process by seeking to re-litigate issues already resolved by an arbitral tribunal and undermine the court’s confirmation of the arbitration award.

  • Devas Multimedia Private Limited v. Antrix Corp. Ltd., No. 20-36024 (9th Cir. Feb. 6, 2024)
    02/06/2024

    Court of Appeals denied petitions for rehearing en banc, finding, contrary to all other federal circuit courts, that in addition to fulfilling the Foreign Sovereign Immunities Act requirements, plaintiffs must prove “minimum contacts” to assert personal jurisdiction over a foreign state, including when enforcing an international arbitration award.

  • Telecom Business Solution, LLC v. Terra Towers Corp., No. 23-144 (2d Cir. Feb. 6, 2024)
    02/06/2024

    Court of Appeals affirmed district court’s ruling confirming the arbitration award because the claims were rightfully governable by the binding arbitration provision in the shareholders’ agreement.  Court of Appeals found defendants failed to establish either that the arbitration panel displayed a manifest disregard for the law or that the arbitration procedure was fundamentally unfair.  Court of Appeals concluded that the panel’s “last-minute switch” from New York law to the AAA rules was not fundamentally unfair because defendants were on notice that the arbitration would be conducted in accordance with the AAA rules.

  • New Frontier Investment AG v. BitCenter, Inc., No. 23-MC-80154-PHK (N.D. Cal. Feb. 6, 2024)
    02/06/2024

    Court denied petition to partially vacate arbitration award under the provisions of the FAA and the New York Convention finding that petitioner failed to show the arbitrator manifestly disregarded Hungarian law, or that the award was completely irrational in light of the parties’ contractual agreement or violated the public policy of either the forum state—California—or the United States.

  • Voltage Pictures, LLC v. Gussi, S.A. de C.V., No. 23-55123 (9th Cir. Feb. 5, 2024)
    02/05/2024

    Court of Appeals affirmed district court’s confirmation of an arbitral award holding that (1) district court had jurisdiction under § 203 of Chapter 2 of the FAA and 28 USC § 1331; (2) district court erred in ruling that California law governed service because federal procedural law generally governs service when a party files in federal district court, however, under federal law, plaintiff sufficiently served defendant; and (3) district court did not abuse its discretion by declining to extend comity to a purported Mexican court order enjoining plaintiff from seeking to confirm the award because defendant did not certify the genuineness of document or the translation.

  • Conti 11. Container Schiffarts-GMBH & Co. KG M.S., MSC Flaminia v. MSC Mediterranean Shipping Company S.A., No. 22-30808 (5th Cir. Jan. 29, 2024)
    01/29/2024

    Court of appeals reversed district court’s decision to confirm a $200 million London arbitration award, finding the district court lacked personal jurisdiction over defendant.  Court of appeals agreed that when assessing personal jurisdiction to confirm an arbitration award under the New York Convention, a court should consider contacts related to the underlying dispute, not just the arbitration itself.  However, it found defendant had not waived its personal jurisdiction defense and that the sole contact with the forum, the loading of tanks in New Orleans, did not confer specific personal jurisdiction over defendant.

  • LLC SPC Stileks v. The Republic of Moldova, No. 14-CV-01921-CRC (D.D.C. Jan. 19, 2024)
    01/19/2024

    Court denied respondent’s motion for relief from judgment pursuant to Rule 60(b) of the Federal Rules of Civil Procedure without prejudice.  Although the court was inclined to agree that such relief was warranted, it held that it would be premature to grant the motion given that plaintiff may appeal the Paris Court of Appeals’ decision vacating arbitration award against respondent in favor of plaintiff’s predecessor-in-interest.

  • Equipav S.A. Pavimentação, Engenharia e Comercio Ltda. v. Bertin, No. 22-CV-04594-PGG (S.D.N.Y. Jan. 18, 2024)
    01/18/2024

    Court granted motion to confirm order of attachment as to respondent’s assets, finding that (i) there was a cause of action; (ii) it was probable that petitioner would succeed on the merits; (iii) one or more grounds for attachment pursuant to NY CPLR § 6201 existed; (iv) the amount demanded from respondent exceeded all counterclaims known to petitioner; and (v) the attachment was needed to obtain jurisdiction and also appropriate to secure payment from respondent.  Court also granted petitioner’s motion to confirm arbitration award against respondent and nonparty and denied respondent’s motion to dismiss for lack of personal jurisdiction, finding it had quasi in rem jurisdiction over respondent’s property located in its district.  Court also denied respondent’s motion for a stay, finding that the Europcar factors weighed in favor of denying a stay.

  • Zhongtie Dacheng (Zhuhai) Investment Management Co Ltd v. Yan, No. 8:22-CV-00461-KK-ADS (C.D. Cal. Jan. 12, 2024)
    01/12/2024

    Court confirmed an arbitral award pursuant to the New York Convention, holding that service was proper because respondents were mailed notice of the proceedings to their last known addresses listed on publicly available documents and their government-issued IDs. 

  • Epicenter Loss Recovery LLC v. Burford Capital Limited, No. 18-CV-03300-DJH (D. Ariz. Jan. 9, 2024)
    01/10/2024

    Court granted defendants’ motion to dismiss following the issuance of a final arbitration award from the LCIA.  Court, having previously stayed litigation pending a final award, did not maintain continued jurisdiction under the LCIA Rules or the FAA, where plaintiff challenged the validity of the award, finding the primary jurisdiction in which to challenge the award would be in the English courts.

  • In re Refinería de Cartagena S.A.S., No. 23-MC-00455-JPC (S.D.N.Y. Jan. 8, 2024) 
    01/08/2024

    Court granted 28 USC § 1782 request for leave to serve document and deposition subpoenas on defendants.  Court reasoned that the discovery requests were relevant and “for use” in foreign restructuring proceedings, and that petitioner qualified as an interested party, as the proposed restructuring plans could discharge debtors from amounts owed to petitioner under an arbitration award.  In weighing the discretionary Intel factors, court did not find the discovery requests to be overly intrusive or burdensome in light of the court ordered modifications limiting the scope of each request.

  • Anhui Light Industries International Co., Ltd. v. Dream Express Inc., 23-CV-05942-RGK-PD (C.D. Cal. Jan. 5, 2024)
    01/05/2024

    Court denied petition to confirm a CIETAC arbitration award under the New York Convention, finding respondent was not a party to the contracts, which were entered into fraudulently in respondent’s name, and therefore, did not consent to arbitration.  

  • BBC Chartering Carriers GMBH & Co., KG, v. Hsin Silk Road Shipping Limited, No. 23-CV-06043-KK-MRW (C.D. Cal. Jan. 4, 2024)
    01/04/2024

    Court granted motion to confirm foreign arbitral award and motion for default judgment pursuant to the award.

  • Jiakeshu Technology Limited v. Amazon.com Services, LLC, No. 22-CV-10119-JGLC (S.D.N.Y. Jan. 3, 2024)
    01/03/2024

    Court denied petitioner’s petition to vacate the arbitral award and granted defendant’s motion to confirm the award, finding petitioner did not rely on any of the grounds under the New York Convention or the FAA on which courts may vacate an arbitral award, instead relying on the “severely limited” manifest disregard standard and other unrecognized bases in the Second Circuit such as “complete irrationality” and violation of “strong public policy.”

  • Andonian v. Soleimani, No. 23-CV-06817-JGLC (S.D.N.Y. Jan. 3, 2024)
    01/03/2024

    Court granted petitioner’s motion to remand to state court finding it lacked subject matter jurisdiction, because there was no arbitral award at issue governed by the New York Convention since the award had already been converted into a judgment.  Court also found that, even if it possessed both subject-matter and removal jurisdiction, it would still abstain from hearing the case because the State of New York had a strong interest in the issues.

  • Lanesborough 2000, LLC v. Nextres, LLC, No. 23-CV-07584-PKC (S.D.N.Y. Jan. 1, 2024)
    01/01/2024

    Court denied petitioner’s emergency motion for a temporary restraining order and preliminary injunction against defendant’s state court action to vacate an arbitration award, finding petitioner failed to show irreparable harm would ensue in the time necessary to adjudicate the motion.

  • Yunnan Duobang Network Technology Co. Ltd. v. Amazon.com Services LLC, No. 23-CV-01137-JCC (W.D. Wash. Dec. 18, 2023)
    12/18/2023

    Court denied motion to vacate arbitration award under the FAA and granted cross-motion to confirm the award, finding arbitrator did not manifestly disregard the law and the arbitration award did not violate public policy.

  • Longyan Junkai Information Technology Co., Ltd. v. Amazon.com Services LLC., No. 1:23-CV-04869-JGK (S.D.N.Y. Dec. 12, 2023)
    12/12/2023

    Court denied petitioner’s motion to vacate and granted respondents’ cross-motion to confirm ICDR arbitral award.  Court declined to remand to state court, finding it had subject matter jurisdiction under the New York Convention, because plaintiff is a foreign corporation.  Court rejected petitioner’s arguments that the award should be vacated because it was irrational, in manifest disregard of the law, and violated public policy. 

  • Valores Mundiales, S.L., and Consorcio Andino, S.L., v. Bolivarian Republic of Venezuela, No. 23-7077 (D.C. Cir. Dec. 8, 2023)
    12/08/2023

    Court of appeals affirmed decision enforcing arbitral award pursuant to the ISCID Convention and 22 USC §1650a.  Court of appeals rejected appellant’s argument that it had been deprived of due process because the ICSID annulment committee declined to recognize counsel designated by a new political regime in Venezuela.

  • Marseille-Kliniken AG v. Republic of Equatorial Guinea, No. 20-CV-03572-RJL (D.D.C. Nov. 17, 2023)
    11/17/2023

    Court confirmed petitioner’s arbitration award, dismissing defendant’s argument that the parties agreed to litigate in an Equatoguinean court before using arbitration as an appeal tribunal.  Court concluded that such procedural preconditions to arbitration were for the arbitrators to decide and that the arbitrators’ decision that they had jurisdiction over the claim should not be disturbed.

  • Galaxia Electronics Co., Ltd. v. Luxmax, U.S.A., 2:16-CV-05144-JAK-GJS (C.D. Cal. Nov. 16, 2023)
    11/16/2023

    Court entered a default judgment against defendants, including for attorneys’ fees, costs, and interest arising out of the parties’ prior international arbitration proceeding. 

  • Next Level Ventures LLC v. Avid Holdings Ltd., 2:23-MC-00052-LK (W.D. Wash. Nov. 14, 2023)
    11/14/2023

    Court denied plaintiff’s application for a writ of execution for the United States Marshal to take possession of and sell certain of defendant’s personal property—including intellectual property, contract rights, or claims of compensation—after court confirmed ICDR award, and defendant appealed the court’s confirmation of the arbitrator’s award without moving for a stay.  Court reasoned that granting a writ of execution would be unjust because plaintiff could in theory purchase the rights at issue through the Marshal’s sale while also destroying the opposing party’s appeal by becoming its owner through enforcement of the very judgment under review.  Court also expressed hesitancy to issue a writ when plaintiff’s application did not specify whether the subject property is located within the state and indicated that the writ would be improper since plaintiff had not given a pre-sale notice to the debtor.

  • RSM Production Corp. v. Gaz du Cameroun, S.A., No. 4:22-CV-03611 (S.D. Tex. Nov. 4, 2023)
    11/04/2023

    Court granted motion to partially vacate portion of arbitration award reducing recovery by roughly $4 million, and confirm the remaining portions of the award where the tribunal reversed course on a substantive legal issue it previously decided.

  • Dow Olefinverbund GmbH v. Trinseo Deutschland GmbH, No. 1:23-CV-07794-LAK (S.D.N.Y. Nov. 1, 2023)
    11/01/2023

    Court confirmed ICDR arbitration award pursuant to the New York Convention where respondent failed to respond, finding petitioner had met its burden of demonstrating that the award should be confirmed.

  • Fujian Shenda Investment Management Co., Ltd. v. Yunxin, No. 23-CV-05888-SB-BFM (C.D. Cal. Oct. 23, 2023)
    10/23/2023

    Court ordered petitioner to show cause why action seeking to confirm foreign arbitral award should not be dismissed for lack of personal jurisdiction over respondent, an individual residing in China.  Court requested petitioner respond providing authority for its position that the court may consider the objective of the lawsuit, to obtain a judgment and seek enforcement of an award by pursuing proceeds of a real estate sale in California, when analyzing specific jurisdiction.

  • UBS Financial Services Inc. v. Gutiérrez, No. 3:21-CV-01277-GMM (D.P.R. Oct. 18, 2023)
    10/18/2023

    Court denied petitioner’s motion to vacate arbitration award and granted defendants’ cross motion to confirm the award.  While one arbitrator failed to disclose five other legal proceedings in which he brought legal actions against large corporations similar to petitioner, the failure to disclose was insufficient to substantiate impartiality that materially prejudiced the arbitration proceedings.  Court further found that there was no manifest disregard for the law in the tribunal’s grant of a recession remedy where petitioner could not show that the arbitrators acted “intentionally in a manner so outside the realm of reasonable legality.”

  • Noble Prestige Limited v. Galle, No. 22-11520 (11th Cir. Oct. 16, 2023)
    10/16/2023

    Court of appeals found it lacked jurisdiction to review district court’s finding on subject matter jurisdiction over a petition to confirm a foreign arbitral award where its decision only dismissed petitioner’s claims against one respondent but left its claims against other respondents pending.  Court of appeals determined it had jurisdiction to review district court’s temporary restraining order, finding that it was actually a preliminary injunction subject to immediate review.  Court of appeals vacated the district court’s order, finding it violated the prior exclusive jurisdiction doctrine, since a Colorado probate court already exercised exclusive jurisdiction over respondents’ property, and the district court lacked the authority to issue a preliminary injunction freezing respondents’ assets under Federal Rule of Civil Procedure 65.

  • Exclusive Trim, Inc. v. Kastamonu Romania, S.A., No. 23-CV-03410-ALC (S.D.N.Y. Oct. 12, 2023)
    10/12/2023

    Court granted petitioner’s petition to confirm and enforce foreign ICDR arbitration award under the New York Convention on the ground that there was no genuine issue of material fact precluding judgment in favor of enforcement, and because respondent neither appeared in the action nor opposed the petition.

  • Strong v. Cashbet Alderney Limited, No. 23-CV-02081-JSC (N.D. Cal. Oct. 11, 2023)
    10/11/2023

    Court granted respondents’ motion to dismiss petitioner’s petition to confirm and enforce foreign ICDR arbitration award under the New York Convention on the ground that petitioner lacked Article III standing.  Court found that petitioner failed to satisfy the injury-in-fact requirement for Article III standing because the arbitration award was fully satisfied long before the petition was filed.

  • BUA International Limited v. Domtec International LLC, No. 23-CV-00206-DCN (D. Idaho Oct. 11, 2023)
    10/11/2023

    Court granted petitioners’ petition to confirm foreign arbitral award and for an entry of judgment on the ground that respondent failed to explicitly invoke any of the seven grounds for refusal in Article V of the New York Convention, and even those defenses that could be implied were without any showing of proof.

  • Eletson Holdings, Inc. and Eletson Corporation v. Levona Holdings Ltd., No. 23-CV-07331-LJL (S.D.N.Y. Oct. 10, 2023)
    10/10/2023

    Court denied respondent’s motion for an order referring the proceeding to enforce a foreign arbitration award to the bankruptcy court on the grounds that respondent is not a debtor or creditor in the bankruptcy proceeding it references; respondent does not contend that the confirmation of an arbitration award is a core proceeding as to which the bankruptcy court has the power to enter a final judgment; and respondent invokes no authority for an Article III court to refer the matter to the bankruptcy court, which does not have Article III powers.

  • BBC Chartering Carriers GMBH & Co. KG v. HSIN Silk Road Shipping Ltd., No. 23-CV-06043-MWF-MRW (C.D. Cal. Oct. 10, 2023)
    10/10/2023

    Court ordered petitioner to show cause why action seeking to confirm, recognize, and enforce foreign arbitral award should not be dismissed for lack of prosecution, requesting either respondent respond to the outstanding petition, or petitioner submit an application to enter default.

  • SinSin Europe Solar Asset Limited Partnership v. SPI Energy Co. Ltd., 2:22-CV-01991-MCE-JDP (E.D. Cal. Oct. 2, 2023)
    10/02/2023

    Court granted petition to confirm arbitration awards under the New York Convention.  Court awarded attorneys’ fees to petitioner based on respondent’s refusal to pay valid arbitral awards, forcing petitioners to bring the instant action.  Court declined to order injunctive relief in the form of a worldwide asset freeze until petitioners could show that respondent is refusing to comply with the court’s orders after judgment has been entered.

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