The U.S. Supreme Court's only treatment of Section 1782, in Intel Corp. v. Advanced Micro Devices Inc., [2] identified four nonexclusive factors a district court should consider in exercising its discretion and it is now essentially de rigueur for every Section 1782 decision to discuss those factors. They are: Prior to the Supreme Court's decision in Intel, there had been two circuit courts that had addressed the issue of whether Section 1782 may be used in aid of private, international arbitration — National Broadcasting Co. v. Bear Stearns & Co. Inc. [3] and Republic of Kazakhstan v. Biedermann International. [4] Both the U.S. Courts of Appeals for the Second and Fifth Circuits held that Section 1782 was not so available.