(b) A court of this state need not recognize a foreign country
judgment if:
1. the defendant in the proceeding in the foreign court did not
receive notice of the proceeding in sufficient time to enable the
defendant to defend;
2. the judgment was obtained by fraud that deprived the losing party
of an adequate opportunity to present its case;
3. the judgment or the cause of action on which the judgment is based
is repugnant to the public policy of this state or of the United States;
4. the judgment conflicts with another final and conclusive judgment;
5. the proceeding in the foreign court was contrary to an agreement
between the parties under which the dispute in question was to be
determined otherwise than by a proceeding in that court;
6. in the case of jurisdiction based only on personal service, the
foreign court was a seriously inconvenient forum for the trial of the
action;
7. the judgment was rendered in circumstances that raise substantial
doubt about the integrity of the rendering courts with respect to the
judgment;
8. the specific proceeding in the foreign court leading to the
judgment was not compatible with the requirements of due process of law;
or
9. the cause of action resulted in a defamation judgment obtained in a
jurisdiction outside the United States, unless the court before which
the matter is brought sitting in this state first determines that the
defamation law applied in the foreign court's adjudication provided at
least as much protection for freedom of speech and press in that case as
would be provided by both the United States and New York constitutions.
(c) A party resisting recognition of a foreign country judgment has
the burden of establishing that a ground for non-recognition stated in
subdivision (a) or (b) of this section exists; provided that the party
seeking recognition shall bear the burden of establishing the adequate
protections for freedom of speech and press required as a condition to
recognition under paragraph nine of subdivision (b) of this section if
the party resisting recognition establishes that the judgment is for
defamation.