What should you call it when a federal court dismisses a case on forum non conveniens (that’s “the forum is not convenient”) grounds, reasoning that it should instead be litigated in Germany? See, e.g., Bonzel v. Pfizer, Inc., 439 F. 3d 1358 (Fed. Cir. 2006), for one such case, which aren’t uncommon, given the broad and deep commercial relations between the U.S. and Germany, and the general soundness of the German legal system, which prevents courts from being reluctant to send cases back there.

The answer: Junker abstention.