The defendant was registered in the Marshall Islands and had taken out a marine insurance policy underwritten by the claimant Lebanese insurer. The policy was subject to English law. It also contained somewhat complicated jurisdictional provisions, to the effect that the defendant was entitled to sue the claimant only in Cyprus, the claimant was entitled to bring proceedings in the courts of any country which had or claimed jurisdiction and the defendant submitted to the non-exclusive jurisdiction of the Cyprus courts, waiving any objection on the basis of forum non conveniens to any proceedings brought in Cyprus or in any other court. After the defendant’s vessel had become a total loss, the claimant sought a declaration from the English court that it was not liable to indemnify the defendant because the event leading to the vessel’s loss was expressly excluded from the scope of the policy. The claimant successfully obtained permission from the English court to serve process on the defendant in the Marshall Islands. The defendant sought to set aside such service on the basis that the English court did not have jurisdiction, arguing in the first place that the claimant was obliged, by virtue of the Hague Choice of Court Convention 2005,2 to sue in Cyprus and, in the alternative, that English law required the claimant to commence proceedings in Cyprus unless there were strong reasons not to do so.