defendant’s vast resources”. Also, Presbyterian Church of Sudan v. Talisman Energy, Inc., 244 F.Supp.2d 289 (S.D.N.Y. 2003) at 341: “A countervailing factor is the relative means of the parties”. In 2006, the 2nd Circuit Federal Court in New York issued a decision in the famous Coca-Cola case. Coca-Cola took over assets of Jews expelled from Egypt in the 1950s and was sued in New York. Bigio v. Coca-Cola Company, 448 F.3d 176 (2d Cir. 2006), certiorari to Sup. Ct. denied. In that case, the plaintiffs were Canadians and non‐residents of New York. The court denied Coca-Cola's FNC motion and the U.S. Supreme Court denied certiorari. The 2nd Circuit stated that the fact that the New York court would need to apply “modest application” of Egyptian law was not a problem because “courts of this Circuit are regularly called upon to interpret foreign law without thereby offending the principles of international comity”. Also, the fact that there were witnesses abroad was not a problem either. They could be flown into the U.S. or Letters Rogatory could be issued to the Egyptian courts to collect their testimony. Further, it was held that in an FNC scenario, a court applies the balance of conveniences, but preference (and weight) must be given to the fact that plaintiffs chose this particular forum for “legitimate reasons”. The fact that plaintiffs could sue in Canada was not relevant because Coca-Cola was a U.S. company and it was “perfectly reasonable to sue in the US”. Europe The doctrine of FNC gained little footing in the civil law world, which prefers the approach of lis alibi pendens (see Articles 21-23 Brussels Convention). The civil law jurisdictions generally base jurisdiction on the residence of the defendant and on choice of law rules favouring the habitual residence of the parties, the lex situs, and the lex loci solutionis (applying actor sequitur forum rei). This reflects an expectation that a defendant should be sued at his "own" courts, modified to reflect different priorities in certain types of case. As an example of this expectation, Article 2 Brussels I Regulation (as well as the corresponding Lugano conventions) provides: But this is subject to the substantial exceptions contained in Articles 3–6, the limitations on insurance actions in Articles 7–12, and consumer contracts in Articles 13–15. Article 16 also grants exclusive jurisdiction to specified jurisdictions as the lex situs of immovable property and a res,