Did you wake up this morning and say: "You know what? I think I want to finally understand the French concept of astreinte. I especially want to know whether it operates as a fine or penalty, or is it instead in the nature of a damage award?"
If so, coincidentally enough, you're in luck. Here's ten single-spaced pages or so on the subject.
Truthfully, the opinion is worth reading even for the more pedestrian intellectuals amongst us. For Judge McKeown also writes ten pages or so about whether a judge is allowed to examine expert declarations on what foreign law entails at the pleading stage; e.g., on a 12(b)(6) motion.
Foreshadowing alert: The answer is "Yes."
Fancy-pants international legal stuff from the Ninth Circuit to begin the week.