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===Historical origin===
Scholars and jurists seem to find a Scottish origin prior to the first American use of the concept.<ref>http://www.mssc.state.ms.us/decisions/Publishedopinions/96-01284.HTM</ref><ref>{{cite web |url=http://www.judicium.it/news/pistis01.html#_edn1
The doctrine of FNC originated in the [[United States]] in ''Willendson v. Forsoket'' [29 Fed Cas 1283 (DC Pa 1801)] (No 17,682) where a federal district court in [[Pennsylvania]] declined to exercise jurisdiction over a [[Denmark|Danish]] sea captain who was being sued for back wages by a Danish seaman, stating that "[i]f any differences should hereafter arise, it must be settled by a Danish tribunal." In [[Scotland]], the concept is first recorded in ''MacMaster v. MacMaster'' (Judgment of 7 June 1833, Sess, Scot 11 Sess Cas, First Series 685.)
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