The answer to this point is that it is arguable chat the exception to the Abouloff v Oppenheimer &Co rule for in rem judgments does not apply where the claim is for wrongful misappropriation, and where the defence is, not that there was an assignment, but that the elements of a claim for unjust enrichment are lacking. It is also arguable that, even if the April and December 2.005 judgments were relied on as assignments, they should not be recognised on public policy grounds, in the light of the way in which Fellowes obtained the judgments in breach of a English arbitration agreement and of orders of the English and BVI courts, and in the light of the way in which the Kyrgyz courts dealt with the case