The Recognition of U.S. Class Action Judgments Abroad: The Case of Latin America

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.

Number of Pages in PDF File: 73

Keywords: class actions, recognition, enforcement, international cooperation, Latin America

Accepted Paper Series