Judge Cobb’s ruling affirmed that the applicable statute of limitations for enforcing judgments is 12 years, as defined by D.C. law. Titan argued that the D.C. code governing enforcement of monetary judgments is the most appropriate analogy for the International Centre for Settlement of Investment Disputes (ICSID) arbitration award. The court concurred, noting that ICSID awards should be treated similarly to state court judgments, as required by 22 U.S.C. Section 1650a, which governs the enforcement of ICSID awards.
“This law establishes a twelve-year limitations period for the enforcement of any ‘final judgment or final decree for the payment of money rendered in the… Superior Court of the District of Columbia,'” Judge Cobb wrote in her opinion.
Argentina’s attempts to dismiss the case held little ground according to the judge. The nation referenced the Federal Arbitration Act’s three-year deadline and the District’s similar statute of limitations. However, the presiding official emphasized that practical enforcement of International Centre for Settlement of Investment Disputes awards took priority. Lengthy annulment proceedings often postponed final rulings, so a condensed window risked redundant concurrent litigation.
