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I am much intrigued by Arthur von Mehren's paper setting out a call for a Hague Judgments Convention.1 I think his proposal for a mixed convention, with green, red, and yellow lights for jurisdiction (or black, white, and shades of gray, if you prefer) is quite ingenious. I like making law-which is why I enjoyed being a Reporter for the Foreign Relations Restatement and why I envy Professor von Mehren his role as prospective drafter of the multilateral judgments convention. For political or negotiating reasons, being a member of the United States delegation, he carefully avoids saying what such a convention should provide. I can well understand that he does not want his proposal to place the item on the agenda of the Hague Conference shot down by someone who does not like a particular provision that might be contained in such a convention. Clearly, as an official U.S. spokesman, Professor von Mehren does not want to negotiate the merits of a multilateral judgments convention before agreement has been reached on the shape of the table. No such constraints apply to me. I am not a spokesman for the United States, nor a member of a delegation, and I cannot imagine that anyone other than my own self would be embarrassed by what I say. Whether the initiative led by Peter Pfund and Arthur von Mehren is worthwhile, however, will depend a good deal on what is said or written at the table, once agreement is reached on its shape. I propose, therefore, to set out here what I think a sound convention on the recognition and enforcement of judgments should contain. My thoughts are the product in part of experience with recognition of judgments in both directions-that is, U.S. judgments abroad and foreign judgments in the United States-in part on experience with the U.N. Convention on the Recognition and Enforcement of Foreign Arbitral Awards (the New York

Thoughts about a Multinational Judgments Convention: A Reaction to the von Mehren Report