On June 13, 2022, the U.S. Supreme Court issued its judgment in ZF Automotive U.S. Inc. et al. v. Luxshare, Ltd., two consolidated cases originating from the Sixth Circuit and involving arbitration proceedings abroad. In both of the cases, a foreign party sought discovery in the U.S. under 28 U.S.C. 1782(a), which allows federal district courts to order discovery of evidence "for use in a proceedings in a foreign or international tribunal." The main issue in these cases was whether arbitration qualified as a "foreign or international tribunal" under the statute and, in both cases, the lower courts permitted the discovery requested. The Supreme Court disagreed, holding that only a "governmental or intergovernmental" tribunal qualifies. According to the Court, "a 'foreign tribunal' is one that exercises governmental authority conferred by a single nation, and an 'international tribunal' is one that exercises governmental authority conferred by two or more nations. Private adjudicatory bodies do not fall within section 1782." On the specific facts of the case, the Court concluded that neither of the adjudicative bodies in question satisfied these definitions because neither were created or prescribed by a government or governments.