Introduction

The United States Court of Appeals for the District of Columbia issued a short but interesting decision on 27 November 2007 in Democratic Republic of Congo (Appellant) v. FG Hemisphere Associates, LLC (Appellee) , ruling on the question of waiver by the Democratic Republic of Congo (DRC) of its objection to service of process under the Foreign Sovereign Immunities Act (FSIA) in connection with the enforcement of arbitration awards against it in the United States. In essence, the Court ruled that because the DRC had actively engaged in litigation against ...