7. In making a decision on forum non conveniens grounds, how much weight should be given to plaintiff’s forum preference? In WIWA v. ROYAL DUTCH PETROLEUM CO., 226 F.3d 88 (2d Cir.2000), three Nigerian émigrés living in the United States sued two foreign holding companies alleging that the companies had participated in human rights violations against them in retaliation for their political opposition to the companies’ oil exploration activities in Nigeria. The Second Circuit reversed the forum non conveniens dismissal and held that the deference due to the forum choice of a United States resident depends on her affiliation with the forum. “[T]he greater the plaintiff’s ties to the plaintiff’s chosen forum,”

the court explained, “the more likely it is that the plaintiff would be inconvenienced by a requirement to bring the claim in a foreign jurisdiction.” Id. at 102. Conversely, absolute deference is not accorded to the forum choice of a United States citizen when the facts show a significant relationship with an alternative forum. See Carey v.Bayerische Hypo–Und Vereinsbank AG, 370 F.3d 234, 238 (2d Cir. 2004) (finding it was not unreasonable to require a United States plaintiff to file suit in Germany, the country in which she had “sought out the relationship that resulted in the suit”).