Has Europe Closed its Doors on U.S. and Canadian Class Action Judgments?
Recent significant developments in Europe suggest more forcefully than ever that class action judgments from the U.S. and Canada will not be recognized or enforced in European countries. The European Parliament has released its long-awaited report on "Towards a Coherent Approach to Collective Redress". An opt-out model of collective redress is soundly rejected in favour of an opt-in model. There are many warnings about avoiding "U.S. style class actions" in Europe. The Danish Court of Appeal has confirmed that its courts have jurisdiction to approve and enforce a Danish class action settlement affecting non-U.S. citizens in multiple European Member states. The Irish Court of Appeal has refused to recognize a foreign judgment from a Swedish court that assumed jurisdiction over some of the parties based on a “real and substantial connection”. Does this mean the end of international, multi-jurisdictional classes in U.S. and Canada?
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