The US District Court for the Northern District of Illinois recently ruled that disclosure under § 1782 was unavailable to aid a “private” ICC tribunal. In Norfolk Southern Corp. v. Gen. Sec. Ins. Co., 626 F. Supp. 2d 882 (N.D. Ill. 2009), the court denied the motion for a court order to depose a party’s former counsel in aid of an ICC arbitration. Relying on the US Supreme Court’s decision in Intel v. Advanced Micro Devices, 542 U.S. 241 (2004), the court strictly interpreted § 1782 to apply only to “state-sponsored arbitral bodies,” thereby excluding “purely private arbitrations.”