The judicial assistance available to foreign governmental agencies in the United States was greatly expanded by the 1964 amendments to the federal assistance statute. Most significant was the insertion of the term "tribunal" to define the type of body which could secure aid from the federal courts. Judicial construction of the new term, however, has presented some difficulties resulting in the denial of assistance to foreign states. This note reviews the policy considerations and legislative history relevant to defining "tribunal," and posits factors to be weighed in establishing a more efficacious "tribunal" test.

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