In a major development that will be welcomed by anyone engaged in pursuing international fraud claims, the Civil Procedure Rules Committee (CPRC) has approved expansions to the gateways for service out of the jurisdiction as set out in Practice Direction 6B (PD 6B), which will come into force this October.

In a highly anticipated decision issued last Thursday (on December 19, 2019), the United States Court of Appeals for the Third Circuit held in In re Millennium Lab Holdings II, LLC that a bankruptcy court may constitutionally confirm a chapter 11 plan of reorganization that contains nonconsensual third-party releases. The court considered whether, pursuant to the United States Supreme Court’s decision in Stern v. Marshall, 564 U.S. 462 (2011), Article III of the United States Constitution prohibits a bankruptcy court from granting such releases.