In U.S.:
A federal court in Los Angeles has recognized a Chinese court judgment of USD 6,500,000 against a California defendant.
The case was decided under the Uniform Foreign Money Judgments Recognition Act (UFMJRA), as adopted by California. The UFMJRA has been adopted by approximately 30 states, including New York, Texas, Delaware, Florida, Georgia, Illinois, Maryland, Massachusetts, New Jersey, and Ohio. Judgments from different civil and common law countries have been recognized and enforced in U.S. courts, but the recent decision to enforce a Chinese court judgment is noteworthy. Similar cases have been met with courts finding reasons to not enforce Chinese court judgments.
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In Germany, Israel, Singapore, New Zealand:
Germany: In a 2006 case, German Züblin International Co Ltd v. Wuxi Walker General Engineering Rubber Co, Ltd34 (hereinafter “German Züblin”), the Court of Appeal of Berlin (hereinafter “Berlin Court”) recognized a Chinese judgment on the invalidity of an arbitral clause.
Israel: The case Jiangsu Overseas Group Co Ltd v. Reitman39 (hereinafter “Jiangsu Overseas Group”) arose out of a Chinese judgment40 seeking recognition in Israel. On 6 October 2015, a Chinese judgment was recognized for the first time in Israel, by the Tel Aviv District Court (hereinafter “Tel Aviv Court”).
Singapore: The 2012 case of Giant Light Metal Technology (Kunshan) Co Ltd v. Aksa Far East Pte Ltd69 (hereinafter “Giant Light Metal Technology”) concerned the recognition and enforcement of a Chinese judgment in Singapore.
New Zealand: Yang Chen v. Jinzhu Lin75 is a 2016 appeal case in which a New Zealand court for the first time recognized a Chinese monetary judgment.
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In Australia:
The Australian common law does not require reciprocity for recognizing and enforcing foreign judgments. Therefore, although Chinese courts have never recognized and enforced an Australian monetary judgment, Australian courts have recognized and enforced Chinese judgments.
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