1. Does Rule 11(b)(1) permit sanctions for papers that are legally and factually well grounded, but submitted for an improper purpose? In Sussman v. Bank of Israel, 56 F.3d 450

(2d Cir. 1995), the Second Circuit reversed the award of sanctions based on a nonfrivolous complaint that had been filed in an inconvenient forum for alleged purpose of compelling settlement of a parallel action brought outside the United States. The court explained that a

“party should not be penalized for or deterred from seeking and obtaining warranted judicial relief merely because one of his multiple purposes in seeking that relief may have been improper.” Id. at 459. See Solovy, Hirsch,655Simpson & Tomaras, Sanctions under Rule 11:

A Cross-Circuit Comparison, 37 Loy. L.A. L. Rev. 727 (2004). Do you agree with this reading of the rule?