Cartels have taken on an increasingly international flavor over the past two decades as multinational corporations have expanded their global operations. The United States is the only jurisdiction in the world in which plaintiffs may obtain treble damages for violations of its antitrust laws. As such, foreign purchasers of goods sold by alleged cartel members are typically eager to file antitrust claims in the United States. But when should they be permitted to do so? The Ninth Circuit Court of Appeals examined this issue in In re: Dynamic Random Access Memory (DRAM) Antitrust Litigation, 08 C.D.O.S. 10595 (9th Cir. Aug. 14, 2008).

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