This update focuses on the forum non conveniens doctrine. Olin has argued that if the Second Circuit is inclined to consider forum non conveniens, it should overrule two of its prior decisions allowing dismissals on that basis, asserting that the doctrine has no application as it relates to foreign arbitral awards. This case could potentially represent an examination of forum non conveniens as it relates to the recognition of foreign arbitral awards, which the Second Circuit has not reconsidered in 25 years.