The United States Court of Appeals for the Second Circuit in New York City overruled its precedent allowing for due process protections for states in the context of a jurisdictional analysis. The September 28, 2009 ruling in the matter Frontera Resources Azerbaijan Corporation v. State Oil Company of the Azerbaijan Republic, docket number 07-1815, involves a conflict between a Cayman Islands company and the state oil agency over the confirmation of a Swedish arbitral award against the state entity. -- Clemens Kochinke, partner, Berliner, Corcoran & Rowe, LLP, Washington, DC.