Portimex’s argument is meritless. Portimex cannot escape the duplicative nature of the breach of contract claims it has asserted in Mexico, which plainly involve the same parties, the same facts and the same causes of action, merely by arguing that different law applies to those contract claims. In both actions, Portimex alleged that Zen-Noh breached the two contracts for the sale of sorghum. Application of the Convention to those allegations does not give rise to any new or different causes of action. Further, even though Portimex had a full and fair opportunity in this Court to argue that the Convention should apply to its breach of contract claims, it never did so, nor did it dispute the Court’s application of Louisiana law. Cf. Betkell v. Peace, 441 F.2d 495, 497 (5th Cir.1971) (<HOLDING>). Because Portimex’s breach of contract action
holding that a foreign representative may assert under  804 only those avoiding powers vested in him by the law applicable to the foreign estate holding that in cases of a false conflict of law a court may apply the law of the forum state holding that a party relying on foreign law must plead and prove it and partys failure to do so entitles court to assume that foreign law is the same as forum law holding under texas version of the recognition act that public policy exception is not triggered simply because the body of foreign law upon which the judgment is based is different from the law of the forum or because the foreign law is more favorable to the judgment creditor than the law of the forum holding that as a matter of law the embassy of a sovereign nation is a foreign state