National Aluminum Co., Ltd. (“NALCO”) prevailed in arbitration held in India against Peak Chemical Corp. in 2005. Ultimately, the award was affirmed on appeal by an Indian court in February 2012. When earlier this year, NALCO attempted to enforce the Indian judgment in a federal district court in Illinois, Peak contended that the judgment was barred by the FAA’s three-year statute of limitations for the recognition of international arbitration awards. The court, however, agreed with NALCO, which distinguished the recognition of the award itself from the recognition of the Indian judgment affirming the award; while the former may be time barred, the latter was still enforceable under Illinois’ 15-year statute of limitations for the enforcement of foreign judgments. The court observed that there was “little case law on the issue,” but that case law from other courts, as well as policy considerations, supported its determination that the FAA does not preempt a state’s power to recognize a former judgment. The court then rejected Peak’s alternative arguments attempting to preclude the recognition of the foreign judgment under Illinois law. National Aluminum Co., Ltd. v. Peak Chemical Corp., Inc., Case No. 1:14-cv-01314 (USDC N.D. Ill. Sept. 23, 2015).