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Forum-shopping: "The light repels the moths"

A federal court in Maryland rebuffs an effort to sue in the United States over melamine contamination in China. [Beck et al] The reference is to a famous line from Britain's Lord Denning: "As a moth is drawn to the light, so is a litigant drawn to the United States. If he can only get his case into their courts, he stands to win a fortune." Smith Kline & French Laboratories, Ltd. v. Block [1983] 2 All E.R. 74 (C.A. 1982) (Denning, M.R.).



Rafael Mangual
Project Manager,
Legal Policy

Katherine Lazarski
Manhattan Institute


Published by the Manhattan Institute

The Manhattan Insitute's Center for Legal Policy.