WESLEY, Circuit Judge:
This appeal requires us to decide whether the "special circumstances" exception to the first-filed rule applies to a declaratory judgment action filed in the absence of a direct threat of litigation in a forum with at least some ties to the litigation. We hold that it does not, and reverse the judgment of the United States District Court for the Southern District of New York (Mukasey, C.J.) and remand for a determination of whether the...
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