Parties have occasionally sought to use findings on jurisdiction made by a court in one country to preclude re-litigation of the same matter elsewhere. In common law countries the traditional means by which this tactic has been employed is the doctrine of issue estoppel. The aim of this article is to assess the extent to which jurisdictional determinations by foreign courts can have binding effects in other countries.

中文翻译：

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外国法院对管辖权决定的承认

缔约方偶尔试图利用一国法院的管辖权调查结果来排除对其他地方同一案件的重新诉讼。在普通法国家中，采用这种策略的传统手段是禁止反言的学说。本文的目的是评估外国法院的管辖权裁决在其他国家可以产生约束力的程度。