would seem clearly to be lighter than the burden on defendant King posed by proceeding in this Court. Finally, considering the interests of comity, judicial economy and avoidance of duplicative litigation, the earlier pendency of litigation in Italy involving substantially similar issues weighs strongly against the exercise of personal jurisdiction by this Court. See NGS American, Inc. v. Jefferson, 218 F.3d 519, 522 (6th Cir.2000) (observing that federal courts frown upon declaratory judgment actions brought for procedural fencing purposes); Smith v. Securities and Exchange Comm’n, 129 F.3d 356, 361 (6th Cir.1997) (noting general principle of avoiding dupli-cative litigation); and Michigan Community Services, Inc. v. National Labor Relations Board, 309 F.3d 348, 356 (6th Cir.2002) (<HOLDING>). Considering the totality of the circumstances
recognizing comity as a golden rule among nations  that each must give the respect to the laws policies and interests of others that it would have others give to its own in the same or similar circumstances recognizing that a contract is to be construed to give reasonable effect to each of its provisions holding that crossdefault provisions in insurance policies were unenforceable because they would impermissibly restrict the debtors ability to assume some of the policies and reject others recognizing that the court must give meaning to all the words in the claims recognizing a similar exception to its rule with respect to corporations