Under 28 U.S.C. § 1782, U.S. federal district courts may grant interested parties discovery “for use in a proceeding in a foreign or international tribunal.” In a unanimous decision issued on June 13, 2022, the U.S. Supreme Court ruled in ZF Automotive US, Inc. v. Luxshare, Ltd., that arbitral tribunals constituted in (i) a private international commercial arbitration or (ii) investor-state disputes under a bilateral investment treaty do not qualify as a “foreign or international tribunal.” The Court held that this phrase only includes governmental or intergovernmental bodies, and that the arbitral panels at issue did not qualify. Accordingly, the parties in those arbitrations could not use Section 1782 to obtain discovery in the United States.