This, like many such cases, is not really a dispute about forum. The connection which this case has with the Isle of Man is that BITEL seeks to enforce a Kyrgyz judgment by proceedings in the Isle of Man against the KFG companies, three companies incorporated in the Isle of Man, who seek to counterclaim against the appellants in relation to matters which occurred E wholly outside the Isle of Man, and primarily in Kyrgyzstan. The KFG companies accept that Kyrgyzstan is the natural forum for the pursuit of their claims, in the sense of being the jurisdiction with which their claims have their most real and substantial connection: Spilioda Maritime Corpn v Cansulex Ltd [1987] AC 460, 478, per Lord Goff of Chieveley.