Your U.S. client has been doing business in a foreign country, but relations with the counterparty have soured and there is now a dispute that cannot be settled. The foreign party has sued in its home court.

Your client has brought its own lawsuit in a local U.S. court. There appears to be a basis for personal jurisdiction in both courts. Your client has received a motion by the counterparty to dismiss the U.S. lawsuit in favor of the foreign counterparty's courts on grounds of forum non conveniens.