The plaintiff and the defendant deliberated before the courts of the State of Florida. The parties reached a settlement agreement, which was approved by the Florida courts. However, while the settlement agreement included a waiver vis-à-vis the defendant’s controlling shareholder, the waiver was not included in the Florida court’s ruling.
The plaintiff sought to enforce the ruling in Israel. The Israeli Supreme Court found that the discrepancy between the settlement agreement and the Florida court’s ruling should be settled by the Florida court, and in any event it did not prevent the enforcement of the ruling in Israel.