Proof of Foreign Law After Bodum

Richard P. Clem Continuing Legal Education
CLE Podcast: $10

This program has been approved by the Wisconsin Board of Bar Examiners for 1.0 credit of Repeated On-Demand credit between the dates of April 8 and December 31, 2011. To view the course approval on the Board's website, follow this link. (The list shown consists of multiple pages, and you might need to move to a different page to view this course.) This program was originally presented on April 7, 2011, as a telephone conference call CLE. This audio program runs approximately one hour. Click Here to View the Course Description

To participate in this online program for CLE credit, please follow the following steps:

  1. Download the written course materials. This is a PDF of six pages: Course Materials (PDF)
  2. Download and listen to the program. The program is available in MP3 format. Follow the following link to download and play the five-part MP3 file:
  3. During the audio program, you will be given three code words. Write down these code words, which you will need to obtain your certificate of completion for CLE credit.
  4. If you have any substantive questions regarding the program, please e-mail them to, and I will respond promptly.
  5. If you desire a certificate of completion, e-mail the three code words to me at, or mail them with your payment to the address below.
  6. Make your payment of $10. You may mail your check to:
    Richard P. Clem
    P.O. Box 14957
    Minneapolis, MN 55414

    If you prefer, you may pay securely online by clicking the "Buy Now" button below. If you have a PayPal account, you will be given the option to sign in with your PayPal ID. If you do not have (or prefer not to use) your PayPal account, you may also pay with a credit card.

Upon receipt of your payment, I will e-mail you a certificate of completion in PDF format. Most certificates of completion will be e-mailed the same day, but please allow 2-3 business days to receive your certificate.

Program Description

This program will discuss the ramifications of the Seventh Circuit’s decision in Bodum USA, Inc., v. La Cafetiere, Inc., 621 F.3d 624 (7th Cir. 2010), and what it means for the practitioner who needs to present the law of a foreign country to a U.S. Court. Two of the three opinions generated by Bodum were critical of the common-law practice of the use of expert affidavits to establish foreign law, even though the practice is permitted by the Federal Rules of Civil Procedure. We’ll look at the common-law antecedents of this decision, the modern practice in various jurisdictions, and how the practitioner should respond to the three somewhat conflicting opinions in Bodum. One hour.

The program is presented by Richard P. Clem. He has a B.A. in history from the University of Minnesota, and a J.D., cum laude, from Hamline University School of Law. He has been in private practice in the Twin Cities for over 20 years. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State,468 N.W.2d 580 (Minn. Ct. App. 1991).

This program will be eligible for CLE credit in the following jurisdictions. Please click on the state name below for further information and any limitations:

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Copyright 2011, Richard P. Clem Continuing Legal Education
PO Box 14957
Minneapolis, MN 55414