11. The law is ever changing; so too are lawyers’ strategic assessments of the relative advantages of litigating in the United States rather than in courts abroad. Indeed, commentary has identified a new trend, dubbed “forum shopper’s remorse”:

Having obtained what they wished for dismissal in favor of a foreign judiciary with a supposedly more pro-defendant legal environment defendants are encountering unexpectedly pro-plaintiff outcomes, including substantial judgments against them. If the plaintiff seeks enforcement of the foreign judgment against the defendant’s assets in the United States, the defendant may then argue that the judgment, or the foreign legal system producing it, suffers from deficiencies that should preclude enforcement an argument seemingly at odds with the defendant’s396earlier forum non conveniens argument that the foreign judiciary was available, adequate, and more appropriate.