Since Piper, not many countries have lived up (or down) to its stringent standard. Among the foreign fora which have been held to be inadequate are: Ghana (Cabiri v. Assasie-Gyimah, 921 F.Supp. 1189 (S.D.N.Y. 1996)); Sudan (Presbyterian Church of Sudan v. Talisman Energy, 244 F.Supp.2d 189 (S.D.N.Y. 2003)); Iran (Rasoulzadeh v. Associated Press, 574 F.Supp. 854 (S.D.N.Y. 1983)); Croatia (Sablic v. Armada Shipping APS, 973 F.Supp. 745 (S.D. Tex. 1997)); Bolivia (Eastman Kodak Co. v. Kavlin, 978 F.Supp. 1078 (S.D. Fla. 1997)); Egypt (Tradimpex Egypt Co. v. Biomune Co., 777 F.Supp.2d 802 (D. Del. 2011)) and Paraguay (HSBC USA, Inc. v. Prosegur Paraguay, S.A., 2004 WL 2210283 (S.D.N.Y. 2004)).Perhaps the most common challenge to a foreign forum is that the country's judicial system is corrupt.