Should this Court extend its holding in Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981) and hold that where a foreign plaintiff has made a well-supported claim for punitive damages against an American corporation for American-based punitive conduct which caused harm abroad, the unavailability of a punitive remedy in an alternative forum shall weigh against dismissal of the case for forum non conveniens?

QUESTIONS PRESENTED (1) Should this Court extend its holding in Piper Aircraft Co. v. Reyno, 454 U.S. 235 (1981) and hold that where a foreign plaintiff has made a wellsupported claim for punitive damages against an American corporation for American-based punitive conduct which caused harm abroad, the unavailability of a punitive remedy in an alternative forum shall weigh against dismissal of the case for forum non conveniens? (2) If a district court finds that there is a wellsupported claim for punitive damages arising out of American-based punitive conduct but determines that the case should be dismissed for forum non conveniens, is the court permitted to implement a return-jurisdiction condition on its dismissal allowing for the punitive damages claim to ultimately be tried in the United States?