¹ The United States officially recognized the Obregon government on August 31, 1923.

² The case presents a striking parallel to State of Yucatan v. Argumedo, 157 N. Y. Supp. 219, 225 (1915). Argumedo, a revolutionary governor of Yucatan, left for New York with 900,000 Mexican gold pesos, after being driven out by Alvarado, an adherent of Carranza, on March 17, 1915. This money he deposited in part in the Woolworth Building Safe Deposit Co., and on October 1, 1915, Yucatan, through representatives of Alvarado, began action in New York to enjoin its removal. A few days later, on October 19, 1915, the United States recognized Carranza as the de facto Government of Mexico. The New York Supreme Court continued the injunction, holding that Yucatan as a foreign state could sue, that Alvarado as the appointee of Carranza properly represented it, and that “it makes no difference that the recognition followed by a few days the initiation of this action, for the recognition of the Carranza government relates back to its inception and all acts of the plaintiff government of Yucatan, such as the bringing of this action, are ratified.”

³ In Wulfsohn v. Russian Socialist Federated Soviet Republic, 192 N. Y. Supp. 282, 195 N. Y. Supp. 472, 1922, the New York Supreme Court permitted the Soviet Government to be sued as a foreign corporation, holding that the usual immunities of a sovereign flowed from comity rather than law and so did not prevent suit against an unrecognized foreign government. This seemed to neglect the fact that with the court’s theory in the Cibrario case the property attached really belonged, not to the Soviet Government, but to Russia which, by the same theory, was not represented in court at all.