Corporations often turn to arbitration to manage risks of being hauled into unfamiliar national courts and unpredictable laws. An often overlooked consequence of choosing arbitration is that available discovery may be limited, as a trade-off to efficiency and cost-saving. But in many civil law jurisdictions such as South Korea, discovery practice may be more limited than arbitral proceedings seated in common law jurisdictions or governed by their laws. In this regard, discovery in U.S. litigation stands out unparalleled. U.S. state and federal civil procedure rules provide access to a broad scope of information and documents for both the prosecuting and defending parties, which could be immensely costly and time-consuming. For this reason, parties engaged in international arbitration have often turned to US courts to obtain a potential treasure trove of evidence under ยง1782 of Title 28 of the United States Code.