In Sinochem International Co. Ltd. v. Malaysia International Shipping Corp., 549 U.S. 422, 434, 127 S. Ct. 1184, 167 L. Ed. 2d 15 (2007) the U.S. Supreme Court answered the question of "whether a federal court can dismiss under the forum non conveniens doctrine before definitively ascertaining its own jurisdiction." It held that when forum non conveniens analysis "weighs heavily in favor of dismissal," it can be conducted prior to subject matter or personal jurisdiction analysis when jurisdictional issues are "difficult to determine." Id. at 436. Because Sinochem instructed that a potentially straightforward forum non conveniens analysis may occur prior to a more rigorous jurisdictional determination, a court may proceed with that analysis if it has jurisdiction over only one of the parties. See id. at 435 ("Discovery concerning personal jurisdiction would have burdened Sinochem with expense and delay.").