In Quaak v. Klynveld Peat Marwick Goerdeler Bedrijfsrevisoren. 361 F.3d 11 (1st Cir. 2004), the first circuit upheld an antisuit injunction ordered against a defendant who sought to have a Belgian court impose a fine on the plaintiff if it attempted to obtain discovery of documents that may (or may not) have been confidential under Belgian law. 361 F.3d at 20. The appellate court found this tactic to be an "attempt to chill legitimate discovery by in terrorem tactics [which could] scarcely be viewed as anything but an effort to quash the practical power of the United States courts." Id. The first circuit also found that the defendant had other options available to it, rather than the imposition of a punitive fine, and that, substantively speaking, the plaintiffs' case in the U.S. District Court was not a mere fishing expedition, which bolstered that court's imposition of an injunction that is generally to be cautiously applied. See id. Finally, the first circuit articulated other factors for consideration, such as the conduct of the parties, the posture of the proceedings, the importance of the policies at stake in the litigation, and the extent to which the foreign action has the potential to undermine the forum court's ability to reach a just and speedy result. Id. at 21. It is evident that the central concern in Quaak underpinning the affirmance of an international antisuit injunction, i.e. the interdictory nature of the proceedings before the foreign court, is not present here. See id. at 18. The first circuit rejected a "wooden" approach that the preservation of the forum court's jurisdiction and the protection of important national policies are the only reasons for granting an international antisuit injunction. Quaak, 361 F.3d at 18. However, those factors remain central to the analysis, and the absence of either in this case makes it difficult to overcome the presumption against concurrent jurisdiction. See id. at 20.