Factors relevant to forum non conveniens (location of parties, witnesses, applicable law, and underlying transaction) cannot, on their own, establish that foreign proceedings are vexatious or oppressive so as to justify an anti-suit injunction. Proceedings that were regular when commenced do not become vexatious or oppressive merely because the sole foreign party is removed, leaving only domestic parties. There is no principle that commencement of proceedings in federal jurisdiction in Australia entitles a party to an injunction restraining foreign proceedings on the same subject matter.
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