The Effect Of A Foreign (US) Judgement On A Claim In Israel

What is the effect of a settlement agreement in a Class Action which was approved by the Court in California, U.S.A. on a Class Action which was filed in Israel by an Israeli claimant against the same defendant, based on the same cause of action?

The Israel Supreme Court dealt in April 2015 with this question (RCA 3973/10 David Stern vs. Verifone Holdings Inc. (2.04.15), and analyzed the issue of enforcement of foreign judgements in Israel.

In principle, unless a foreign judgement has undergone a process of enforcement or recognition by an Israeli Court, it has no standing, not for its execution nor for the creating of a res judicata, which may bar litigation of the same issues between the same parties.