Disputes over the ownership of artwork today tend to lead to litigation characterized by complex fact patterns, multiple parties, and a host of implicated jurisdictions. Consider a case where an Argentine citizen purchases an antique Italian tapestry in Switzerland, then lends it to a museum in the United States, and finally is threatened with suit by a Colombian citizen, who claims the object was stolen while in transit from Belgium. Most litigators would immediately ask, “What court has jurisdiction?” and then, “Which jurisdiction is best for my client?”
