This Note will first examine the general purpose of the Foreign Sovereign Immunities Act and attempt to ascertain the intended meaning of the direct effect clause. It will then compare and contrast the Nikkei court's interpretation of the clause with the interpretations used in the other recent cases in the Southern District involving Nigerian cement contract disputes. Finally, this Note will suggest that the approach used in Nikkei is both correct and consistent with congressional intent as manifested in the legislative history of the Act.
J. Blair Richardson, Jr.,
The Nikkei Case: Toward a More Uniform Application of the Direct Effect Clause of the Foreign Sovereign Immunities Act,
4 Fordham Int'l L.J. 109
Available at: http://ir.lawnet.fordham.edu/ilj/vol4/iss1/5