5. Should an international tribunal such as the International Court of Justice, the World Trade Organization, or the United Nations Compensation Commission ever be an acceptable alternative forum for purposes of forum non conveniens? In NEMARIAM v.

FEDERAL DEMOCRATIC REPUBLIC OF ETHIOPIA, 315 F.3d 390 (D.C. Cir.2003), certiorari denied 540 U.S. 877, 124 S.Ct. 278, 157 L.Ed.2d 141 (2003), the D.C. Circuit held it was an abuse of discretion to dismiss for forum non conveniens when the alternative forum was a Claims Commission designed to resolve war-related suits involving Ethiopia and Eritrea. Relief in the Claims Commission was subject to offset by amounts due from one nation to the other. The court found that “it would be peculiar indeed to dismiss * * *

[plaintiff’s] claim in the United States District Court a forum in which * * * she is certain to be awarded full relief if she wins on the merits of her claim in favor of a forum in which she has no certainty of getting relief for a meritorious claim.” Id. at 395.

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