Noah Rubins is an Associate, international litigation and arbitration practice, Jones, Day, Reavis & Pogue, Washington, D.C.; J.D., Harvard Law School; M.A.L.D., Fletcher School of Law and Diplomacy; A.B., Brown University. I am deeply grateful to Arthur von Mehren for his supervision and invaluable assistance in the original draft of this article. I would also like to thank Barry Garfinkel, John Gardiner and Dana Freyer of Skadden, Arps in New York for their insightful comments and support.