In National Broadcasting Co. v. Bear Stearns & Co., the Second Circuit focused on the statute's legislative history in ruling that "there was no question" that the statute applied only to intergovernmental tribunals or other state-sponsored adjudicatory bodies. Likewise, in Republic of Kasakhstan v. Biedermann Int'l, the Fifth Circuit ruled that "[r]eferences in the United States Code to 'arbitral tribunals' almost uniformly concern an adjunct of a foreign government or international agency." Both decisions stressed policy concerns regarding the application of § 1782 to international arbitration—namely, (a) imposing burdensome discovery on parties that agreed to arbitration in order to avoid this issue; and (b) parties attempting to use U.S. courts for a tactical advantage. The Sixth Circuit followed a different analytical path in Abdul Latif Jameel Transp. Co., focusing on statutory interpretation while questioning the reliability of legislative history.