Recently, in ZF Automotive US v. Luxshare, 596 U.S. __, 142 S.Ct. 2078 (2022), the U.S. Supreme Court decided two consolidated cases in which international parties, who were engaged in private arbitration, had moved federal district courts to enforce discovery orders against third parties residing in the United States. The court unanimously held that under 28 U.S.C. Section 1782(a), a federal district court is not authorized to compel a resident within the court's jurisdiction to testify or produce documentation for use in a private arbitration abroad. See ZF Automotive, 142 S.Ct. at 2089. For the purposes of Section 1782(a), a district court may only assist in discovery "for use in a proceeding in a foreign or international tribunal," and the "private" arbitral panels governing the subject arbitrations did not qualify as that type of "tribunal" because they had derived no authority from a "governmental adjudicative body."