What Can the United States Learn from English Anti-Suit Injunctions? An American Perspective on Airbus Industrie GIE v. Patel

Abstract

This Comment provides a look at the US. legal system through the eyes of England's highest court. Using the House of Lords decision in Airbus Industries GIE v. Patel as a vehicle, this Comment discusses the standard for granting international antisuit injunctions in the United States. Along the way, the Comment also offers some practical lessons regarding complex international litigation drawn from the extensive maneuverings employed in the Airbus case as it traveled through various courts in the United States, India, and England. The Comment concludes by arguing that United States courts should embrace the approach advocated by the House of Lords in Airbus and adopt a strict comity-based standard for granting international anti-suit injunctions.