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Comity will be withheld when it would be prejudicial to an interest of the U.S. (e.g. if it would violated 1st amendment)
? Equity principle (Criticized for being a conclusion not a principle)
? Somporex- Ct recognized UK judgment por comity
Reasons for Comity
? Reciprocity, justice, reasonable expectation of the businesses, stability, efficiency, inconsistent judgments
Choice of Law
Steps to take in a conflict (is this order right?)
? 1. Is there a conflict between the choices of law? Is there an actual conflict?
o Look at the two laws to see if they conflict
? 2. Choice of law rule
o use the forum's procedural choice of law rule to determine what choice of law rule is used
o In NY, they use the greatest interest analysis- who has the greatest interest in the case (very fact specific)...
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