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Introduction Parties to private international commercial arbitrations outside of the United States occasionally need help when it comes to evidence production in their arbitral proceedings. One tool to help these parties, particularly if such documents, materials, or individuals sought for deposition are located in the United States, has been § 1782 actions in U.S. courts. To date, there has been a circuit split among courts in the United States as to whether a private international arbitration falls within the scope of § 1782(a) to allow for parties to such an arbitration to utilize § 1782 actions. However, that may all change soon, as the U.S. Supreme Court has granted cert to hear a

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