United States, and a foreign country, e.g. Canada, the prevailing concept is comity. The Court in the United States, in most cases, will unilaterally enforce the foreign judgment, without proof of diplomatic reciprocity, either under judge-made law or under specific statutes. Recognition will generally be denied if the judgment is substantively incompatible with basic legal principles in the recognizing country. For example, U.S. courts, in accordance with the Securing the Protection of our Enduring and Established Constitutional Heritage Act, are prohibited from recognizing or enforcing foreign libel judgments against any United States person unless the foreign country in which the judgement was made protects freedom of speech to at least the same degree as the United States and the foreign court's conduct of the case in which the judgement was reached respected the due process guarantees of the U.S. Constitution to the same extent as a U.S. court would have. Exercise of jurisdiction in recognition cases If the country that issued the judgment and the country where recognition is sought are not parties to the Hague Convention on Foreign Judgments in Civil and Commercial Matters (as of December 2017, only ratified by Albania, Cyprus, Kuwait, the Netherlands and Portugal ), the Brussels regime (all European Union countries, as well as Iceland, Norway and Switzerland) or a similar treaty or convention providing for the routine of registration and enforcement between states, the courts of most states will accept jurisdiction to hear cases for the recognition and enforcement of judgments awarded by the courts of another state if the defendant or relevant assets are physically located within their territorial boundaries. Whether recognition will be given is determined by the lex fori, i.e. the domestic law of the court where recognition is sought, and the principles of comity. The following issues are considered: Whether the foreign court properly accepted personal jurisdiction over the defendant; Whether the defendant was properly served with notice of the proceedings and given a reasonable opportunity to be heard which raises general principles of natural justice and will frequently be judged by international standards (hence, the rules for service on a non-resident defendant outside the jurisdiction must match general standards and the fact that the first instance court's rules were followed will be irrelevant if the international view is that the local system is unjust); Whether the proceedings were tainted with fraud; and Whether the judgment offends the public