The Second Circuit's refusal to enjoin Ecuadorian plaintiffs from enforcing their $18 billion judgment against Chevron left the company's investment arbitration against Ecuador as its first global line of defense. It will be a tough defense for both Ecuador and the plaintiffs to overcome.

The dispute mushroomed to more than 100 court cases in Poland, about 30 cases in other forums, nine commercial arbitrations, and a pair of investment arbitrations. Marcin Olechowski of Warsaw's SK&S, who represented Elektrim, which sought a controlling stake in PTC, compared it to a game of pick-up sticks. "At a certain point all the proceedings became interconnected," he said. "Every time something moved, the whole geometry changed."