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As a matter of fact, they do. They can apply Trademark Law, and thus their decision apply in the US - thanks to Trademark treatises. Thus, once they had decide

As a matter of fact, they do. They can apply Trademark Law, and thus their decision apply in the US - thanks to Trademark treatises. Thus, once they had decided on an the registrar had really no option but to oblige and transfer the website. The registrar could have contested the decision and asked for its exequatur in the US, but it would have been a waste of time, and he could have been subject to penalties in France, but also in the US.

tripletao 8y ago
That's not how American law works. An American registrar is under no obligation to comply before American judicial review. Nothing in American law would have subjected them to penalties if they'd told France to go get an American court order, which they would happily comply with. France can of course impose whatever penalties it wants (and collect them to the best of its abilities). I'm pretty sure it works the same in the other direction, too. Do judgments work like that within the EU? I'm wondering if the unusually close relationship among EU countries gives EU citizens a misleading picture of international law in general. > Before a US court will enforce a judgment issued by a foreign court, the US court must first recognize the judgment. To “recognize” a foreign judgment means to make it equal to any other judgment issued by a US court. A foreign judgment recognized by a US court—a domesticated judgment—has the same authority as a judgment first issued in the United States. Foreign judgments cannot be enforced in the US before they are recognized. https://harrisbricken.com/blog/recognition-foreign-judgments-us-courts/ https://harrisbricken.com/blog/recognition-foreign-judgments...