The U.S. Supreme Court held that, under § 1782, "foreign or international tribunals" refers to governmental or intergovernmental adjudicative bodies. The Court's decision, authored by Justice Amy Coney Barrett, resolves the Circuit split on whether § 1782 can be used in aid of private commercial arbitrations. In finding that investor-state tribunals constituted under the UNCITRAL Rules also do not fall within the scope of § 1782, the Court's decision departs from prevailing case law in the district courts, such as In re Oxus Gold PLC, MISC 06-82-GEB, 2007 WL 1037387 (D.N.J. Apr. 2, 2007) and In re Chevron Corp., 749 F. Supp. 2d 141, 144 (S.D.N.Y. 2010).