In the

United States Court of Appeals

For the Seventh Circuit

Nos. 99-3195, 99-4064, 00-1066, 00-1371,

00-1430 & 00-1702

The Society of Lloyd’s,

Plaintiff-Appellee,

v.

James Frederick Ashenden, et al.,

Defendants-Appellants.

Appeals from the United States District Court

for the Northern District of Illinois, Eastern Division.

Nos. 98 C 5335, 99 C 2651--Harry D. Leinenweber, Judge.

Argued September 19, 2000--Decided November 27, 2000

 Before Posner, Manion, and Kanne, Circuit Judges.

 Posner, Circuit Judge. These are diversity suits

brought in the federal district court in Chicago

by Lloyd’s, a foreign corporation (see Haynsworth

v. The Corporation, 121 F.3d 956, 958 (5th Cir.

1997)), against American members ("names") of

insurance syndicates that Lloyd’s manages. 28

U.S.C. sec. 1332(a)(2). Lloyd’s wanted to use the

Illinois Uniform Foreign Money-Judgments

Recognition Act, 735 ILCS 5/12-618 to 626, to

collect money judgments, each for several hundred

thousand dollars, that it had obtained against

the defendants in an English court after the

names’ repeated efforts in earlier litigation to

knock out the forum-selection clause in their

contracts with Lloyd’s had failed. Bonny v.

Society of Lloyd’s, 3 F.3d 156 (7th Cir. 1993);

Lipcon v. Underwriters at Lloyd’s, 148 F.3d 1285

(11th Cir. 1998); Richards v. Lloyd’s of London,

135 F.3d 1289 (9th Cir. 1998); Haynsworth v. The

Corporation, supra; Allen v. Lloyd’s of London,

94 F.3d 923 (4th Cir. 1996); Roby v. Corporation

of Lloyd’s, 996 F.2d 1353 (2d Cir. 1993).

Pursuant to this strategy, Lloyd’s filed the

judgments in the district court and then issued

"citations" pursuant to the Illinois procedure

for executing a judgment. The filing of the

judgments inaugurated this federal-court

proceeding to collect them; and state law, in

this case the Illinois citations statute, 735
ILCS 5/2-1402, supplies the procedure for

executing a federal-court judgment. Fed. R. Civ.

Pro. 69(a); Resolution Trust Corp. v. Ruggiero,

994 F.2d 1221, 1226 (7th Cir. 1993); 12 Charles

A. Wright, Arthur R. Miller & Richard L. Marcus,

Federal Practice and Procedure sec. 3012, p. 148

(1997). The statute allows the holder of a

judgment to depose the judgment debtor respecting

the existence, amount, and whereabouts of assets

that can be seized to satisfy the judgment; to

impose a lien on those assets; and to command the

debtor to turn over to the judgment creditor as

many of the seizable assets as may be necessary

to satisfy the judgment. See Bank of Aspen v. Fox

Cartage, Inc., 533 N.E.2d 1080, 1083 (Ill. 1989).

 The defendants ignored the citations and instead

asked the district court not to recognize the

English judgments as being enforceable in

Illinois. They argued that those judgments had

denied them due process of law and therefore were

not enforceable under the foreign money-judgments

recognition act, which makes a judgment rendered

by a court outside the United States

unenforceable in Illinois if "the judgment was

rendered under a system which does not provide

impartial tribunals or procedures compatible with

the requirements of due process of law." 735 ILCS

5/12-621 (emphasis added); see also 5/12-620. The

district court rejected the argument and granted

summary judgment for Lloyd’s, declaring the

judgments enforceable and so the issuance of

citations proper.

 We have italicized the word that defeats the

defendants’ argument. The judgments about which

they complain were rendered by the Queen’s Bench

Division of England’s High Court, which

corresponds to our federal district courts; they

were affirmed by the Court of Appeal, which

corresponds to the federal courts of appeals; and

the Appellate Committee of the House of Lords,

which corresponds to the U.S. Supreme Court,

denied the defendants’ petition for review. Any

suggestion that this system of courts "does not

provide impartial tribunals or procedures

compatible with the requirements of due process

of law" borders on the risible. "[T]he courts of

England are fair and neutral forums." Riley v.

Kingsley Underwriting Agencies, Ltd., 969 F.2d

953, 958 (10th Cir. 1992); to same effect see

Haynsworth v. The Corporation, supra, 121 F.3d at

967; Roby v. Corporation of Lloyd’s, supra, 996

F.2d at 1363. The origins of our concept of due

process of law are English, Dent v. West

Virginia, 129 U.S. 114, 123 (1889); Hurtado v.

California, 110 U.S. 516, 528-32 (1884); Coniston

Corp. v. Village of Hoffman Estates, 844 F.2d

461, 465 (7th Cir 1988); Keith Jurow, "Untimely

Thoughts: A Reconsideration of the Origins of Due
Process of Law," 19 Am. J. Legal Hist. 265

(1975), and the English courts, especially the

Supreme Court of Judicature (composed of the High

Court and the Court of Appeal) and the Appellate

Committee of the House of Lords, the tribunals

involved in the judgments challenged here, are

highly regarded for impartiality,

professionalism, and scrupulous regard for

procedural rights. The English judicial "system .

. . is the very fount from which our system

developed; a system which has procedures and

goals which closely parallel our own." In re

Hashim, 213 F.3d 1169, 1172 (9th Cir. 2000),

quoting Somportex Ltd. v. Philadelphia Chewing

Gum Corp., 318 F. Supp. 161, 166 (E.D. Pa. 1970),

aff’d, 453 F.2d 435 (3d Cir. 1971). "United

States courts which have inherited major portions

of their judicial traditions and procedure from

the United Kingdom are hardly in a position to

call the Queen’s Bench a kangaroo court." British

Midland Airways Ltd. v. International Travel,

Inc., 497 F.2d 869, 871 (9th Cir. 1974).

 Not that the English concept of fair procedure

is identical to ours; but we cannot believe that

the Illinois statute is intended to bar the

enforcement of all judgments of any foreign legal

system that does not conform its procedural

doctrines to the latest twist and turn of our

courts regarding, for example, the circumstances

under which due process requires an opportunity

for a hearing in advance of the deprivation of a

substantive right rather than afterwards. See

Hilton v. Guyot, 159 U.S. 113, 205 (1895);

Ingersoll Milling Machine Co. v. Granger, 833

F.2d 680, 687-88 (7th Cir. 1987). It is a fair

guess that no foreign nation has decided to

incorporate our due process doctrines into its

own procedural law; and so we interpret "due

process" in the Illinois statute (which,

remember, is a uniform act, not one intended to

reflect the idiosyncratic jurisprudence of a

particular state) to refer to a concept of fair

procedure simple and basic enough to describe the

judicial processes of civilized nations, our

peers. The statute requires only that the foreign

procedure be "compatible with the requirements of

due process of law," and we have interpreted this

to mean that the foreign procedures are

"fundamentally fair" and do not offend against

"basic fairness." Id. at 687-88; see also Hilton

v Guyot, supra, 159 U.S. at 202-03; Wilson v.

Marchington, 127 F.3d 805, 811 (9th Cir. 1997);

Guinness PLC v. Ward, 955 F.2d 875, 900-01 (4th

Cir. 1992); Banco Minero v. Ross, 172 S.W. 711,

714-15 (Tex. 1915).

 We’ll call this the "international concept of

due process" to distinguish it from the complex

concept that has emerged from American case law.
We note that it is even less demanding than the

test the courts use to determine whether to

enforce a foreign arbitral award under the New

York Convention, 9 U.S.C. sec. 201 et seq., whose

due process defense (that a party lacked "proper

notice of the appointment of the arbitrator or of

the arbitration proceedings or was otherwise

unable to present his case," Article V(1) (b), 9

U.S.C. sec. 201) has been interpreted to mean the

enforcing jurisdiction’s concept of due process,

albeit a rather minimal such concept. Iran

Aircraft Industries v. Avco Corp., 980 F.2d 141,

145-46 (2d Cir. 1992); see also Generica Ltd. v.

Pharmaceutical Basics, Inc., 125 F.3d 1123, 1129-

31 (7th Cir. 1997).

 It is true that no evidence was presented in the

district court on whether England has a civilized

legal system, but that is because the question is

not open to doubt. We need not consider what kind

of evidence would suffice to show that a foreign

legal system "does not provide impartial

tribunals or procedures compatible with the

requirements of due process of law" if the

challenged judgment had been rendered by Cuba,

North Korea, Iran, Iraq, Congo, or some other

nation whose adherence to the rule of law and

commitment to the norm of due process are open to

serious question, see, e.g., Bank Melli Iran v.

Pahlavi, 58 F.3d 1406, 1411-12 (9th Cir. 1995);

Choi v. Kim, 50 F.3d 244, 249-50 (3d Cir. 1995);

Banco Minero v. Ross, supra, 172 S.W. at 715;

Bridgeway Corp. v. Citibank, 45 F. Supp. 2d 276,

286-89 (S.D.N.Y. 1999), as England’s are not. It

is anyway not a question of fact. It is not,

strictly speaking, a question of law either, but

it is a question about the law of a foreign

nation, and in answering such questions a federal

court is not limited to the consideration of

evidence that would be admissible under the

Federal Rules of Evidence; any relevant material

or source may be consulted. Fed. R. Civ. P. 44.1;

Pittway Corp. v. United States, 88 F.3d 501, 504

(7th Cir. 1996); 9 Charles A. Wright & Arthur R.

Miller, Federal Practice and Procedure sec. 2446

(1995).

 Rather than trying to impugn the English legal

system en gross, the defendants argue that the

Illinois statute requires us to determine whether

the particular judgments that they are

challenging were issued in proceedings that

conform to the requirements of due process of law

as it has come to be understood in the case law

of Illinois and other American jurisdictions. The

statute, with its reference to "system," does not

support such a retail approach, which would

moreover be inconsistent with providing a

streamlined, expeditious method for collecting

money judgments rendered by courts in other
jurisdictions--which would in effect give the

judgment creditor a further appeal on the merits.

The process of collecting a judgment is not meant

to require a second lawsuit, see Bank of Aspen v.

Fox Cartage, Inc., supra, 533 N.E.2d at 1083;

Resolution Trust Corp. v. Ruggiero, supra, 994

F.2d at 1226, thus converting every successful

multinational suit for damages into two suits

(actually three, as we’ll see at the end of this

opinion). But that is the implication of the

defendants’ argument. They claim to be free to

object in the collection phase of the case to the

procedures employed at the merits phase, even

though they were free to challenge those

procedures at that phase and indeed did so.

 Even if the retail approach is valid--and we

want to emphasize our belief that it is not--it

cannot possibly avail the defendants here unless

they are right that the approach requires

subjecting the foreign proceeding to the

specifics of the American doctrine of due

process. They are not right. Just as no judgments

of a foreign legal system would be enforceable in

Illinois if the system had to conform to the

specifics of the American doctrine of due

process, so very few foreign judgments would be

enforceable in Illinois if the proceeding in

which such a judgment was rendered had to conform

to those specifics. In a case decided by a

foreign court system that has not adopted every

jot and tittle of American due process (and no

foreign court system has, to our knowledge, done

that), it will be sheer accident that a

particular proceeding happened to conform in

every particular to our complex understanding of

due process. So even the retail approach, in

order to get within miles of being reasonable,

would have to content itself with requiring

foreign conformity to the international concept

of due process.

 And now let us for the sake of completeness

apply that concept to the particulars of these

judgments.

 A bit of background (much simplified): Lloyd’s,

contrary to popular understanding, is not an

insurer, but rather the overseer of the London

insurance market. The actual insurance is written

by syndicates of "names." The syndicates do not

have limited liability, and so the personal

assets of the names are at risk should an insured

obtain a judgment for more than the assets of the

syndicate that insured him. In the late 1980s and

early 1990s the Lloyd’s-supervised syndicates

incurred huge underwriting losses that threatened

to destroy the London insurance market. To ward

off this disaster the governing body of Lloyd’s,

a Council elected primarily by the managing
agents of the syndicates, created a company

called "Equitas" to reinsure the risks

underwritten by the syndicates. The reinsurance

would both protect the insureds against being

unable to collect the proceeds of their insurance

policies from the syndicates and protect the

names from unlimited personal liability for the

underwriting losses. To finance the new company,

Lloyd’s levied an assessment (the reinsurance

premium) against all the names. Lloyd’s offered a

discount on the assessment to induce the names to

go along with this plan voluntarily, and 95

percent of them did. The defendants are among

those who did not, and Lloyd’s sued them in the

High Court to collect the assessment. The suit

was based on the contract with Equitas, Lloyd’s

Council having (pursuant to a by-law that it had

adopted) appointed "substitute agents" for all

the names, and these agents having signed the

contract on behalf of the defendants as of the

other recusant names.

 In the English court the defendants opposed

Lloyd’s suit on the basis of two clauses which

they contend would, if enforced, deny them due

process of law; and they renew the contention

here. The first clause, the "pay now sue later"

clause as the parties call it, forbids names, in

suits (such as the ones before us) by Lloyd’s to

collect the assessment, to set off against the

claim by Lloyd’s any claim the names might have

against Lloyd’s, such as a claim that the

contract had been induced by fraud. If they want

to press such a claim they have to file a

separate suit. (Some have now done so, and lost.

Society of Lloyd’s v. Jaffray, 2000 WL 1629463

(Queen’s Bench Division Commercial Court Nov. 3,

2000).) The second clause, the "conclusive

evidence" clause, makes Lloyd’s determination of

the amount of the assessment "conclusive" "in the

absence of manifest error." The defendants claim

that the High Court refused to order Lloyd’s to

provide them with enough information about how

the assessment had been calculated to enable them

to prove manifest error.

 Both clauses therefore curtail the names’

procedural rights. But due process is not a fixed

menu of procedural rights. How much process is

due depends on the circumstances. For the

principle, see Gilbert v. Homar, 520 U.S. 924,

930-31 (1997), and Mathews v. Eldridge, 424 U.S.

319, 335 (1976), and for applications see, e.g.,

United States v. All Assets & Equipment of West

Side Building Corp., 188 F.3d 440, 443-44 (7th

Cir. 1999); Caldwell v. Miller, 790 F.2d 589,

608-09 (7th Cir. 1986); United States v. Any &

All Radio Station Transmission Equipment, 218

F.3d 543, 550 (6th Cir. 2000). Faced with looming

disaster, Lloyd’s reasonably deemed it essential
to obtain adequate funding for Equitas. The only

potential source for such funding consisted of

the names themselves. If they were entitled to

set off any claims they might have against

Lloyd’s, the collection of the full assessment

would be deferred until those claims could be

adjudicated. The pay now sue later clause was

designed to enable Equitas to be fully funded

immediately. That would work to the benefit of

the names by giving them surer, earlier, and

fuller reinsurance. In exchange it was reasonable

to ask them to postpone the enforcement of any

claims they might have against Lloyd’s. Instead

Lloyd’s has had to prosecute these suits and many

like them to collect from the names. Were it not

for the pay now sue later clause, many other

names might have forced Lloyd’s into collection

litigation as well.

 In these circumstances the clause did not

violate international due process or, we add

unnecessarily, domestic due process. It is the

same procedure used by federal law when a firm

withdraws from a multiemployer pension plan--the

firm is required to pay the plan administrator’s

assessment of the firm’s share of vested but

unfunded benefits and to reserve any objections

for a subsequent suit, Multiemployer Pension Plan

Amendments Act, 29 U.S.C. sec.sec. 1399(c)(2),

1401(d); Robbins v. Pepsi-Cola Metropolitan

Bottling Co., 800 F.2d 641, 642 (7th Cir. 1986)

(per curiam)--and this procedure ("pay now,

dispute later," id.) has survived due process

challenge, see, e.g., Debreceni v. Merchants

Terminal Corp., 889 F.2d 1, 3-4 (1st Cir. 1989).

Anyway the question is not whether Lloyd’s

accorded due process to the names, but whether

the English courts did. All they did was enforce

the clause, and they did so on the basis of an

interpretation of a provision of the original

contract between the names and Lloyd’s that

authorized Lloyd’s to take measures unilaterally

to prevent the society from failing. Stated

differently, the courts held that the names had

waived their procedural rights in advance, thus

bringing the case within the rule of D.H.

Overmyer Co. v. Frick Co., 405 U.S. 174 (1972).

That case upheld against a due process challenge

similar to that mounted by the names in this case

the enforcement of a cognovit note, by which a

debtor consents in advance to the creditor’s

obtaining a judgment against him on the note

without notice or hearing, and possibly even--to

make the analogy to the present case even closer-

-with the appearance on the debtor’s behalf, to

confess judgment, of an attorney designated by

the creditor. Id. at 176. The English courts’

interpretation of the original contract with the

names as authorizing the pay now sue later clause

could not be thought so unreasonable an

interpretation of that contract as to take the
case out from under Overmyer by demonstrating the

absence of a genuine waiver. And this is to

assume that reasonableness in contract

interpretation could ever be a component of due

process, which we greatly doubt, as we’re about

to explain.

 The rationale for the conclusive-evidence

clause, and for the denial of full discovery

regarding the accuracy of the assessment, is

similar to the rationale for the pay now sue

later clause. If the names could resist ponying

up the assessment until its accuracy was

determined by the normal process of litigation,

with pretrial discovery followed by pretrial

motions and by trial, the funding of Equitas

would be delayed. But this clause does more than

postpone claims by the names; it extinguishes

them by shrinking the names’ entitlement to a

right to the rectification of only those errors

that leap out from the assessment figure itself

with no right to pretrial discovery to search out

possible errors in the actuarial or other

assumptions that generated the figure. This

extinction of rights could raise a question if

what we are calling international due process had

a substantive component. But the defendants do

not argue that it does. Though we cannot find a

case on the point, the cases that deal with

international due process talk only of procedural

rights. See, e.g., Wilson v. Marchington, supra,

127 F.3d at 811. The only substantive basis that

the Uniform Foreign Money-Judgments Recognition

Act recognizes for not enforcing a foreign

judgment is that "the cause of action on which

the judgment is based is repugnant to the public

policy" of Illinois, 735 ILCS 5/12-621; see,

e.g., Ingersoll Milling Machine Co. v. Granger,

supra, 833 F.2d at 686-88; cf. Loucks v. Standard

Oil of New York, 120 N.E. 198, 201 (N.Y. 1918)

(Cardozo, J.), a claim the plaintiffs have

abandoned in this court.

 If Parliament passed a law that the Equitas

premium was whatever Lloyd’s Council said it was,

this would not be a denial of a procedural right

of any of the names, but rather a revision of the

substantive terms of the names’ relation to

Lloyd’s. But if Parliament went further and

precluded the names from challenging in court the

applicability of the new law to them, that would

be a curtailment of their procedural rights, and

doubtless a deprivation of their property without

due process of law. But this is not what

happened. Lloyd’s appointed agents to negotiate a

contract binding the names that (they argue) was

disadvantageous to them. It was disadvantageous

in part because it reserved to Lloyd’s a very

broad discretion to fix the premium for the new

reinsurance. But a one-sided contract is a
substantive, not a procedural, offense. (Nor, to

recur for a moment to the pay now sue later

clause, is an unreasonable contractual

interpretation a procedural violation.) The names

were free both to challenge the clause and to

show if they could "manifest error" in the

assessment of their liability under it. They

could not show this, but only because manifest

error is hard to prove. It would have to be an

error that was obvious because of the

disproportion between the reinsurance premium

levied by Lloyd’s and the risk to which the

particular name would be exposed if he lacked

reinsurance. Their real objection to the

exclusive-evidence clause, moreover, is that it

curtails pretrial discovery, and the right to

pretrial discovery is not a part of the U.S.

concept of due process, e.g., Midway Motor Lodge

v. Innkeepers’ Telemanagement & Equipment Corp.,

54 F.3d 406, 408 (7th Cir. 1995); Silverman v.

CFTC, 549 F.2d 28, 33 (7th Cir. 1977); Alexander

v. Pathfinder, Inc., 189 F.3d 735, 741 (8th Cir.

1999), let alone of international due process.

See, e.g., Hague Convention, art. 23 (reprinted

at 28 U.S.C. sec. 1781); Panama Processes, S.A.

v. Cities Service Co., 500 F. Supp. 787, 800

(S.D.N.Y. 1980), aff’d, 650 F.2d 408 (2d Cir.

1981); Rio Tinto Zinc Corp. v. Westinghouse,

[1978] A.C. 547 (H.L.); Gary B. Born,

International Civil Litigation in United States

Courts 843-55 (1996).

 And again the key question is not the fairness

of Lloyd’s measures but the fairness of the

English court in holding that Lloyd’s was

authorized by its contract with the names to

appoint agents to negotiate a contract that would

bind the names without the names’ consent. This

interpretation of the original contract, like the

interpretation authorizing Lloyd’s to adopt the

pay now sue later clause, is not so unreasonable

that it could be thought a denial of

international due process even if international

due process had a substantive component.

 We conclude that the judgments are enforceable

under the foreign money-judgments statute, and we

turn now to the other issues presented by these

appeals. Several of the appellants were

defendants in a separate suit brought by Lloyd’s

against dissenting names that was reassigned to

the district judge (Judge Leinenweber) handling

the other suits because it was identical to those

suits. He granted judgment on the pleadings for

Lloyd’s in the separate suit. The defendants in

that suit argue that the grant was erroneous,

because Lloyd’s had submitted evidence in support

of the motion and Fed. R. Civ. P. 12(c) provides

that when this is done the motion for judgment on

the pleadings is automatically converted to a
motion for summary judgment and the defendants

argue that, so reconceived, the motion should not

have been granted until the defendants had a

chance to put in their own evidence. The issue is

moot. The suits are identical, and the defendants

have not advised us of any evidence that would

affect our determination that the judgments

obtained by Lloyd’s in England are enforceable

under English law.

 The separate appeal by Collins is frivolous and

requires no discussion at all, and we proceed to

the last issue, a challenge to the citations

issued by Lloyd’s in aid of its judgments. Since

we are affirming the district court’s order

allowing Lloyd’s to collect its judgments and

hence to issue citations in aid of that

collection effort, the challenge to the already

issued citations may seem moot. But it is not,

because Lloyd’s may seek sanctions for contempt,

the defendants having refused to comply with the

citations. The issue of the validity of the

sanctions could be deferred to the contempt

proceeding, if any, but we think it best to try

to wind up this litigation by resolving the issue

now. It is not difficult to resolve. The

defendants’ argument is that in the case of a

foreign judgment, as distinct from a judgment

rendered by another jurisdiction within the

United States, citations may not be issued until

a court has entered an order recognizing (that

is, declaring enforceable) the judgment that the

citations are in aid of. We cannot see any legal

or practical basis for such a two-step, and it is

in tension with Ill. S. Ct. R. 277(a), which

states that citation proceedings "may be

commenced at any time with respect to a judgment

which is subject to enforcement." Proceedings are

"commenced" simply by an oral or written request

to the clerk to issue citations. Ill. S. Ct. R.

277(b). The clerk does not investigate to see

whether the judgment is truly enforceable. The

issue of the judgment’s enforceability is raised

by way of defense to compliance with, not

commencement of, the citations proceeding--which

is what happened here. There is no reason to make

the judgment creditor bring two separate

proceedings, one to enforce the judgment and the

other to collect it.

 Any doubt on this score is dispelled by reading

in tandem the statutes governing enforcement of

foreign-state and foreign-nation judgments

respectively. The Illinois Enforcement of Foreign

Judgments Act, which governs the enforcement in

Illinois of judgments rendered in the courts of

other states of the United States, as distinct

from foreign nations, not only treats such

judgments the same as Illinois judgments, 735

ILCS 5/12-652(a), which means that no separate
step of "recognition" is necessary before they

can be enforced; the act also makes the foreign

judgment enforceable unless the judgment debtor

objects and invokes "procedures, defenses, and

proceedings for reopening, vacating, or staying"

the judgment. This clearly implies that separate

"recognition" proceedings are not required--an

interpretation confirmed in cases from other

jurisdictions that have adopted the Uniform

Enforcement of Foreign Judgments Act. Redondo

Construction Corp. v. United States, 157 F.3d

1060, 1065 (6th Cir. 1998); Burchett v. Roncari,

434 A.2d 941, 943 (Conn. 1980). The Uniform

Enforcement of Foreign Money-Judgments Act, which

governs judgments of courts outside the United

States, makes such judgments, if enforceable at

all, "enforceable in the same manner as the

judgment of a sister state which is entitled to

full faith and credit." 735 ILCS 5/12-620. Q.E.D.

Affirmed.