8.2 Theoretical Foundation of Recognition and Enforcement of Foreign Judgment

1. The comity-theory (the Story's-classic): the respect-not-obligation (the sovereign's- courtesy (the Dutch-origin's (the practical's-power (the vagueness's-critique)))); 2. The obligation-theory: the duty's (the territorial's-and-the-justice's (the judgment's-merit- demanding (the international-law's-claim (the proof's-difficulty)))); 3. The vested-rights-theory: the right's-vested (the foreign-judgment's-creation (the forum- protects (the Beale's-USA-face (the fiction's-critique)))); 4. The modern's-local-law-theory (the forum-creates-the-equivalent (the Eaton's-lore (the pragmatic's))); the doctrine's-function (the explanation-vs-the-justification (the exam's-balance: the comity-as-the-usage (the theory-as-the-coat-rack))).