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N DEC. 4, 2001, in Iragorri v. United Technologies Corp.,[1] the U.S. Court of Appeals for the Second Circuit, sitting en banc, issued an important decision regarding the law of forum non conveniens. Traditional forum non conveniens analysis has centered for over a half century on the basic principles set out by the U.S. Supreme Court in Gulf Oil Corp. v. Gilbert.[2] These principles require that a plaintiff’s choice of forum be given deference which can be disturbed only where certain public and private interest factors weigh heavily in favor of an adequate alternative forum.

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