The Sixth Circuit concluded that the DIFC-LICA arbitration panel qualified as a "foreign or international tribunal." Among other things the court found that dictionary definitions supported a broad reading of the word "tribunal" to include private arbitration panels. The court also found support in court decisions that predated the statute for a broad interpretation of the word. Accordingly, the Sixth Circuit held that the word "tribunal" included private, contracted-for arbitration and that the DIFC-LICA panel was a "foreign or international tribunal" within the meaning of 28 U.S.C. § 1782 (a). This year, in March 2020, the Fourth Circuit (which includes Maryland, North Carolina, South Carolina, and Virginia) reached the same result as the Sixth Circuit. Servotronics, Inc. v. Boeing Co., 954 F.3d 209, 210 (4th Cir. 2020) involved discovery sought in South Carolina in aid of a private arbitration in the United Kingdom under the rules of the Chartered Institute of Arbitrators.