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Forum Non Conveniens: Whose Convenience and Justice?*

Many cases analyzing forum non conveniens have found its adequate-alternative-forum requirement is satisfied merely because a defendant is amenable to process in a proposed alternative jurisdiction. As a result, U.S. courts have come to use the doctrine of forum non conveniens to dismiss cases despite the fact that no adequate alternative forum can or will actually hear the plaintiffs ' claims. In Abdullahi v. Pfizer, Inc., the Southern District of New York dismissed one such case after finding Nigerian courts were adequate to hear tort claims against a U.S. corporate defendant. If the court h…

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