Titan Consortium 1 LLC v Argentine Republic - United States Court of Appeals for the District of Columbia Circuit 25-7007 - 21 July 2026

Country
Year

2026

Summary

MILLETT, Circuit Judge: In 2008, after years of tightening regulations on the airline industry, Argentina took over several private airlines from three Spanish investment companies. The investors, alleging that they had been the victims of expropriation in violation of a bilateral international treaty between Argentina and Spain, took Argentina to arbitration.

The investors applied to arbitrate at the International Centre for Settlement of Investment Disputes ("Centre"). The Convention on the Settlement of Investment Disputes between States and Nationals of Other States established the Centre as an international arbitration forum to resolve investment disputes between private individuals and sovereign nations.

The Centre is affiliated with the World Bank, and is located at the Bank's headquarters in Washington, D.C.

After a lengthy arbitration process, the Centre's tribunal awarded the investors over $320 million from Argentina. Two years later, the Centre's internal appellate committee affirmed the award and added more than $1 million in additional costs.

The investors sold their title to this award to Titan Consortium 1, LLC. Titan petitioned the district court for enforcement of the award just over four years after the initial award issued. The district court denied Argentina's motion to dismiss and entered summary judgment in Titan's favor enforcing the award.

Argentina appeals solely on the ground that Titan's petition was untimely. Because 22 U.S.C. § 1650a, the federal law implementing the Convention, lacks a statute of limitations, this court must decide what statute of limitations to apply. Argentina urges the application of the three-year statute of limitations in the Federal Arbitration Act or, in the alternative, the District of Columbia's three-year catchall statute of limitations. Titan argues that the district court correctly applied the District's twelve-year statute of limitations for the enforcement of money judgments issued by courts within the District of Columbia, D.C. Code § 15-101.

Because D.C. Code Section 15-101 provides the closest parallel to Section 1650a, we affirm the district court's holding that D.C.'s twelve-year statute of limitations is the appropriate limitations period to borrow, making Titan's enforcement action timely.

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