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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 5/2023: Abstracts

Conflict of Laws

Gruber: A plea against ex post-adaptation of spousal inheritance rights Adaptation is recognized as a tool to eliminate the lack of coordination between the provisions of substantive law derived from different legal systems. The OGH has found such exception in the Hague Convention 2005 on Choice of Court Agreements.

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Lex & Forum 4/2021: A special on the 2019 Hague Convention on the Recognition of Foreign Judgments

Conflict of Laws

Professor Kerameus started his academic career at the Law School of the Aristotle University of Thessaloniki, in his home town, and completed his career at the University of Athens. He taught Civil Procedure, Comparative and International Procedural Law in Greek and other leading Universities abroad.

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Review of: PP Penasthika, Unravelling Choice of Law in International Commercial Contracts: Indonesia as an Illustrative Case Study (The Hague: Eleven Publishers 2022)

Conflict of Laws

The monograph predominantly examines 19 Indonesian court decisions on choice of law in international commercial contracts during the period, 2000-2020. Conversely, Chapter One also acknowledges the book’s limitations, namely, that it only covers the express choice of law in international commercial contracts.

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One Year of Pandemic-Driven Video Hearings at the German Federal Court of Justice in International Patent Matters: Interview with Federal Judge Harmut Rensen, Member of the Tenth Panel in Civil Matters

Conflict of Laws

I allow myself to pick up a few elements from this fascinating interview in the following for our international audience: The Tenth Panel functions as a court of first appeal ( Berufungsgericht ) in patent nullity proceedings and as a court of second appeal for legal review only ( Revisionsgericht ) in patent infringement proceedings.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 2/2025: Abstracts

Conflict of Laws

It presents newly adopted legal instruments and summarises current projects that are making their way through the EU legislative process. It also refers to the laws enacted at the national level in Germany as a result of new European instruments. Such a court decision can be recognised in Germany under procedural law.

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The Dubai Supreme Court on Indirect Jurisdiction – A Ray of Clarity after a Long Fog of Uncertainty?

Conflict of Laws

Concretely, the court being asked to recognize and enforce a foreign judgment evaluates whether the foreign court had proper jurisdiction to hear the dispute. The term “indirect” distinguishes this concept from its legal opposite: direct jurisdiction. 968/2020 of 7 April 2021 ). 415/2021 of 30 December 2021 ).

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2021: Abstracts

Conflict of Laws

Supreme Court decision in March 2021 in Ford vs. Montana now permits the exercise of specific jurisdiction when the claim arises out of or is (sufficiently) “related” to the defendant’s in-state contacts and activities. The decision also deals with questions of German procedural law. The long-awaited U.S.