On February 13, 2020, Matt McLaughlin published "The Second Circuit Adds Muscle and Extraterritorial Reach to Title 28 U.S.C. § 1782" in Mealey's Litigation Report: Discovery. The following is an excerpt:
Litigators with international practices are generally aware that Title 28 U.S.C. § 1782 can be a potent weapon when gathering documents and testimony located in the United States for use in a foreign proceeding. Section 1782, which has existed in different versions since 1855, empowers federal courts to assist in obtaining evidence for use in "a foreign or international tribunal." Prior to 2004, section 1782 was employed relatively infrequently and, when used, the evidence procured in the United States was almost always used in a traditional court-based lawsuit abroad.