Collision Communications, Inc. v. P Nokia Solutions and Networks OY, 2025 DNH 011 (2025)

Citation: Collision Communications, Inc. v. P Nokia Solutions and Networks OY, 2025 DNH 011 (2025)
Parent Document: Collision Communications, Inc. v. P Nokia Solutions and Networks OY, 2025 DNH 011 (2025)
Jurisdiction: New Hampshire (state)
Effective Date: 2025-01-31
Original Source: https://www.courtlistener.com/opinion/10697928/collision-communications-inc-v... ↗

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But Nokia is incorporated in Finland; therefore, its dissolution is governed by Finnish
law. Federal Rule of Civil Procedure 44.1 governs determinations of foreign law.
Under that rule, “the court is free to insist on a complete presentation” of foreign law
from the party raising the issue. Fed. R. Civ. P. 44.1, adv. comm. notes; see also 9A
Arthur R. Miller, Federal Practice & Procedure: Civil § 2444 (3d ed.) (“The rule
recognizes that judges are reluctant to research and determine foreign law without
some assistance from the attorneys and Rule 44.1 does not obligate them to undertake
that burden.”). In support of its contention, Collision has provided this court with
three pages excerpted from an unknown and uncertified document that purport to
translate sections of a Finnish act to English. See doc. no. 360-7. Collision has not
provided this court with other authorities on Finnish law, such as an affidavit from
an expert in Finnish law. See, e.g., Hartford Fire Ins. Co. v. CNA Ins. Co. (Europe)
Ltd., 678 F. Supp. 2d 1, 8 (D. Mass. 2010); see also Miller, supra § 2444 (noting that
expert testimony generally comprises “the basic mode of proving foreign law”).
Collision’s argument as to the circumstances in which Finnish law permits a
corporation to terminate its corporate existence is insufficiently developed and is
therefore not entitled to further consideration at this juncture. See United States v.

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