This article by Frank Silvestri of Verrill adds to the interest surrounding the U.S. Supreme Court’s grant of certiorari in Servotronics, Inc. v. Rolls-Royce PLC, by positing that Justice Alito’s failure to participate in the cert decision may signal his future recusal on the merits, giving rise to the prospect that the Court will split 4-4 and leave undecided “the question of whether a foreign private arbitration panel is a ‘foreign or international tribunal’ for purposes of 28 U.S.C. § 1782.”