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GBC Oil v. Albania, Memorandum Opinion of the United States District Court for the District of Columbia, March 6, 202

6 Mar 2026
GBC Oil Company Ltd. v. Albania, Albpetrol, ICC Case No. 22676/GR
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Memorandum Opinion of the United States District Court for the District of Columbia
Document Details:
LISTED PARTICIPANTS
Memorandum Opinion of the United States District Court for the District of Columbia
Participants listed are for this document only and may not include all participants involved in the entire case. Always consult the original documents.
Claimant appointee
Respondent appointee
Tribunal/Panel chair
Arbitrator(s)
Sole Arbitrator
ICSID Annulment Committee president
ICSID Annulment Committee members
WTO Appellate Body members
WTO Appellate Body chair
Judges
Loren L. AliKhan
Claimant's counsel
Claimant's law firm
Respondent's counsel
Respondent's law firm
Other counsel
Claimant's expert
Claimant's expert firm
Respondent's expert
Respondent's expert firm
Claimant's witness
Respondent's witness
Other witnesses
Tribunal secretary
Tribunal assistant
Third-party funder
Entities
Omni Bridgeway Limited, Albpetrol, National Agency of Natural Resources, Albania
Country
United States
Print reporter
Document Summary
Memorandum Opinion of the United States District Court for the District of Columbia
This summary note is machine-generated. Always consult the original materials.

Procedural Posture

This Memorandum Opinion, issued by the United States District Court for the District of Columbia, addresses a motion filed by Omni Bridgeway Limited seeking an order under 28 U.S.C. § 1610(c) to authorize the attachment and execution of property belonging to the Republic of Albania and its state-owned instrumentalities. The motion follows the court's prior confirmation of a July 2020 International Chamber of Commerce (ICC) arbitral award and the subsequent entry of a default judgment against the respondents in February 2025.

Legal Issues and Notice Requirements

The principal legal issue before the court was whether the petitioner had satisfied the stringent notice requirements of the Foreign Sovereign Immunities Act (FSIA), specifically 28 U.S.C. § 1608(e), and whether a "reasonable period of time" had elapsed since the entry of judgment to permit attachment under § 1610(c). The court conducted a detailed analysis of the hierarchical service methods prescribed by the FSIA for both foreign states and their agencies or instrumentalities.

Court's Analysis and Findings

The court found that the petitioner properly exhausted the available methods of service. After Albania's Central Authority failed to execute service or provide a certificate of service pursuant to the Hague Service Convention, the petitioner permissibly resorted to service via the Clerk of Court under §§ 1608(a)(3) and (b)(3)(B). The court determined that the dispatch of translated judicial documents via FedEx, which yielded signed delivery receipts, strictly complied with the FSIA's statutory requirements for serving a foreign sovereign and its instrumentalities.

Decision and Operative Relief

Having established that proper notice was effectuated by April 2025, the court evaluated the temporal requirement of § 1610(c). Noting that over a year had passed since the entry of the default judgment and more than ten months since the completion of service, the court held that a reasonable period of time had elapsed. Accordingly, the court granted the petitioner's motion, authorizing attachment and execution against the respondents' property in the United States.