The Second Circuit has acknowledged that New York Judiciary Law Section 489 (descended from an 1813 statute) appears to facially prohibit "essentially all 'secondary' transactions in debt instruments where the purchaser had an intent to enforce the debt obligation through litigation," but then ruled in a 1999 decision involving Elliott Management's earlier case against Peru that the history of that section as interpreted in New York state courts revealed that it was intended only to prohibit purchases made with the "sole" intent of bringing a lawsuit "in and of itself". That is, the New York Legislature was trying to stop attorneys or debt collectors from exploiting cost-shifting clauses in worthless promissory notes to obtain judgments for minuscule amounts (i.e., the face value of the notes) that also awarded massive costs incurred in the course of litigation. Section 489 does not apply to purchases made with the primary intent of collecting on the face value of the instrument, where litigation is merely a means to that end. The United Kingdom, however, restricted the use of its courts for suits by vulture funds against developing countries in 2011. As of 2014 70% of the world's sovereign bonds are issued in New York, and 22% in London.