Alberta Says Nyet! Limitation Act Declares Russian Arbitral Award DOA: Supreme Court to Give Kiss of Life‘
Bibliographic record
Abstract
The recent decision of the Alberta Court of Appeal in Yugraneft v Rexx, refusing recognition and enforcement of a Russian international commercial arbitration award because of an Alberta two year time bar, has caused considerable controversy. The Supreme Court of Canada granted leave to appeal on February 26, 2009. The author examines the basis for the decision, including the appropriateness of applying the Alberta Limitation Act, of equating foreign judgments with simple judgment debts rather than domestic judgments for enforcement purposes, and whether foreign arbitral awards should be subject to any limitation period. The author canvasses alternatives that might be considered by the Supreme Court.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.005 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.000 | 0.001 |
| Science and technology studies | 0.009 | 0.002 |
| Scholarly communication | 0.007 | 0.001 |
| Open science | 0.002 | 0.002 |
| Research integrity | 0.009 | 0.007 |
| Insufficient payload (model declined to judge) | 0.009 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".