By Richard Cooper and Boaz Morag ( January 9, 2018, 1:12 PM EST) -- On Jan. 3, 2018, the U.S. Court of Appeals for the Third Circuit dealt a significant blow to Crystallex International Corp.'s long-running effort to recover its $1.2 billion arbitral award and judgment against the Republic of Venezuela for appropriating Crystallex's rights to the Las Cristinas gold mine. In a 2-1 decision, the Third Circuit — reversing a decision of the Delaware district court that allowed Crystallex to allege a Delaware fraudulent transfer claim against a Delaware corporation wholly owned by the Venezuelan state-owned oil company Petróleos de Venezuela SA, or PDVSA — decided that under Delaware law, a nondebtor transferor cannot be liable for a fraudulent transfer under the Delaware Uniform Fraudulent Transfer Act, or DUFTA....