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U.S. Court Issues Worldwide Anti-Enforcement Injunction
This post was written by Hannah Buxbaum, the John E. Schiller Chair in Legal Ethics and Professor of Law at the Indiana University Maurer School of Law in the United States.
Last month, Judge Edward Davila, a federal judge sitting in the Northern District of California in the United States, granted a motion by Google for a rare type of equitable relief: a worldwide anti-enforcement injunction. In Google v. Nao Tsargrad Media, a Russian media company obtained a judgment against Google in Russia and then began proceedings to enforce it in nine different countries. Arguing that the judgment was obtained in violation of an exclusive forum selection clause, Google petitioned the court in California for an order to block Tsargrad from enforcing it.
As Ralf Michaels and I found in a recent analysis, the anti-enforcement injunction is an unusual but important device in transnational litigation. There aren’t many U.S. cases involving these orders, and one of the leading decisions arose in the context of the wildly complicated and somewhat anomalous Chevron Ecuador litigation. As a result, there is little U.S. authority on a number of important questions, including the legal standard that applies to this form of relief and the mix of factors that courts should assess in considering its availability. Judge Davila’s decision in the Google case addresses some of these questions.
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Tatlici v. Tatlici: Malta Rejects $740 Million U.S. Defamation Judgment as Turkish Case Looms
Written by Fikri Soral, Independant Lawyer, Turkey; and LL.M. student, Galatasaray University, Turkey
A Maltese court has refused to enforce a $740 million default judgment issued by the 15th Judicial Circuit Court of Florida (Palm Beach County) in a defamation suit brought by Applicant Mehmet Tatlici against his half-brother, Defendant Ugur Tatlici. [1] The Florida court’s award—issued on 8 January 2020 in a defamation suit filed by Mehmet Tatlici against his half-brother—was deemed procedurally deficient and substantively incompatible with Malta’s public policy, particularly due to its lack of reasoning and its chilling effect on free expression.[2] Read more
The Personal Status Regimes in the UAE — What’s New and What Are the Implications for Private International Law? A Brief Critical Appraisal
Prologue
On 15 April 2025, the new federal UAE law on personal status (Federal Decree Law No 41 of 14 October 2024) officially entered into force ( “2024 PSL”). This law fully replaces the 2005 Federal Act on Personal Status (Federal Law No. 28 of 19 November 2005 as subsequently amended) (“2005 PSL”). The new law marks the latest step in the UAE remarkable wave of legal reforms, particularly regarding personal status matters. It follows a series of significant developments at both the federal and local levels. At the federal level, this includes the adoption of the law on Civil Personal Status (Federal Decree-Law No. 41 of 3 October 2022 on Civil Personal Status) (“2022 CPSL”) and its executive regulation. At the local level, specific legislations were adopted in the Emirate of Abu Dhabi, most notably the 2021 Law on Civil Marriages and its Effects (as subsequently amended) (“2021 ADCML”), and its Procedural Regulation. These legislative efforts collectively address what is commonly referred to as “civil family law” (for further details see previous posts on this blog here, here, here, and here). Together with the new 2024 PSL, these instruments will collectively be referred to as the “Family Law Regulations” (see Table below). Read more
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New book and webinar Sustaining Access to Justice – 5 September
In June the volume “Sustaining Access to Justice: New Avenues for Costs and Funding” was published in the Civil Justice Systems series of Hart Publishing (2025). The book is edited by Xandra Kramer, Masood Ahmed, Adriani Dori and Maria Carlota Ucín. This edited volume results from a conference held at Erasmus University Rotterdam, as part of the Vici project on Affordable Access to Justice funded by the Dutch Research Council (NWO). It contains contributions on access to justice themes, in particular costs and funding of litigation, by key experts across Europe, Latin America and Asia. More information, including the table of contents is available at the Bloomsbury website here.
The book explores the dynamic landscape of legal costs and financing from three perspectives: regulatory frameworks in public and private funding; new trends and challenges in contemporary legal financing; and the transformative potential of alternative dispute resolution (ADR) and online dispute resolution (ODR) procedures to streamline civil justice processes and expand access to justice.
By addressing the intersectionality of legal, economic, political, market and social dynamics, the book aims to provide an encompassing understanding of the inherent complexity of costs and funding of litigation, and their implications for access to justice.
A seminar on the ocassion of launching the book will take place on 5 September 2025, from 10-12.15 CET.
Program
10.00 Introduction Xandra Kramer, Masood Ahmed, Carlota Ucin, Adriani Dori
10.15 Jacek Garstka (European Commission) – EC perspective on the access to justice and the role of litigation funding
10.25 Maria Jose Azar-Baud – Trends in Funding of Collective Litigation
10.35 Alexandre Biard – Enforcing Consumer Rights: Costs and Funding
10.50 Discussion
11.10 Eduardo Silva de Freitas – Justice for a Price: Funders, Fees and the RAD
11.20 Marcel Wegmüller – ESG and Litigation Funding: A Practitioner’s View
11.35 Adrian Cordina – Regulating Litigation Funding: A Law and Economics View
11.45 Stefaan Voet/Masood Ahmed – Beyond Litigation: Cost-Effective Strategies for ADR and ODR
12.00 Discussion and Conclusion
More information and (free) registration here.
Webinar: Beyond State Borders, Beyond the Situs Rule? Private International Law Issues of Resource Extraction in Antarctica, the Deep Seabed, and Outer Space
The Aberdeen Centre for Private International Law & Transnational Governance (CPILTG) will be hosting a webinar by Professor Caroline Rapatz (University of Kiel, Germany) on 20 August 2025, 11am – 12pm noon.
More information is available here.
ZEuP – Zeitschrift für Europäisches Privatrecht 3/2025
A new issue of ZEuP – Zeitschrift für Europäisches Privatrecht is now available and includes contributions on EU private law, comparative law and legal history, legal unification, private international law, and individual European private law regimes. The full table of content can be accessed here: https://rsw.beck.de/zeitschriften/zeup. 
The following contributions might be of particular interest for the readers of this blog:
- Pacta Sunt Servanda’s Soliloquy Amidst Sanctions: The Impact of EU Sanctions on Contractual Performance in Arbitration Proceedings
Helmut Ortner, Veronika Korom and Marion on the Impact of EU Sanctions on Contractual Performance in Arbitration Proceedings: EU sanctions against Russia and Russia’s countermeasures have significantly disrupted trade, supply chains, and contractual relations, sparking disputes frequently resolved through arbitration. European legal systems provide a range of mechanisms—including force majeure, impossibility, frustration, and hardship—to address sanctions-related performance impediments. Despite doctrinal divergences, these frameworks tend to converge on practical outcomes. To mitigate risks and increase legal certainty, parties are well-advised to incorporate tailored clauses in their contracts. - Eigentumsvorbehalte in grenzüberschreitenden Warenkaufverträgen mit englischen Käufern
Insa Stephanie Jarass on retention of title clauses in contracts with English buyers: In PST Energy 7 Shipping LLC v OW Bunker Malta Ltd (The Res Cogitans) [2016] UKSC 23, the Supreme Court held that the Sale of Goods Act 1979 no longer applies to certain con-tracts containing retention of title clauses which had previously always been categorised as contracts for the sale of goods. This article analyses the legal implications of this decision for contracts for the supply of goods to Eng-land. In addition to the legal uncertainties that have always surrounded the validity in rem of retention of title clauses under English law, the decision adds a new level of complex-ity at the contractual level that requires par-ticular attention when drafting international contracts. - Die europäische vis attractiva concursus – Altbekanntes, Neues und Ungeklärtes zu Reichweite, Kompetenzkonflikten und materieller Sperrwirkung
Fabian Kratzlmeier comments on the decision by the ECJ in C-394/22, addressing the law applicable in the context of insolvency proceedings.