Introduction

Courts, commentators, and commercial actors have long touted arbitration as the best means of resolving international commercial disputes, largely because arbitration - with its many international and regional treaties on enforcement of awards[1] - is a much more efficient and reliable means of recovering against a foreign entity than litigation is.[2] However, the international arbitral regime will soon face a new challenge as class arbitration - a U.S.-initiated dispute resolution mechanism that has been in existence domestically since the early 1980s[3] - becomes increasingly ...