What is the current state of the law in this circuit regarding forum non conveniens?

Moreover, the history of Grammenos v. Lemos, 457 F.2d 1067 (2d Cir. 1972), makes clear that the precise issue now before us remained an open one in this circuit, at least up until Grammenos was decided. In that case, two Greek citizens sued a Panamanian corporation and a Greek citizen, allegedly a resident of New York. The Southern District dismissed the complaint because of defective service and on the ground of forum non conveniens. This court reversed on the issue of service of process and pointed out that forum non conveniens was not appropriate at that time. Most significantly for this appeal, the opinion originally said that forum non conveniens could not be utilized because the alternate forum, Greece, was not available without the consent of the defendant, citing Hoffman v. Blaski. ¹² However, after the opinion was filed, but before publication in the Federal Reporter, the opinion was revised to delete the reference to Hoffman v. Blaski and the proposition for which it had been cited. The revised opinion states, 457 F.2d at 1074 n.5: