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After reading and reviewing a thought-provoking book on the choice of law in international commercial contracts in Indonesia last year, I decided to delve further into the subject by picking up a book on Indonesian private international law. This principle similarly applies in the context of choice of law. Luis F.S.S.
Should courts in the United States refuse to recognize and enforcement Chinese court judgments on the ground that China does not provide impartial tribunals or procedures compatible with the requirements of due process of law? Last April, a NewYork trial court said yes in Shanghai Yongrun Investment Management Co. Wan , a U.S.
Neil Andrews (University of Cambridge), Procedure, Party Agreement, and Contract (in English). Having chosen instead (b) arbitration, the parties will normally make explicit the ‘seat’ (London, Milan, NewYork, etc) and the size of the arbitral tribunal (one, three, five, etc).
Martinez: These cases can be highly complex and involve huge multinationals with global contracts and disputes based on large monetary claims and may include IP issues. We know this because when we receive their awards we see their experience through and the quality of their analysis of the case and application of the law.
The first panel will focus on global and comparative private international law. The second panel will examine contemporary English conflict of laws, through the lens of Trevor’s famous ICLQ article on the systematic dismantling of the common law of conflict of laws.
10), which according to Franzina was designed not primarily with civillaw systems in mind, but rather for common law jurisdictions, who were assumed to have difficulties in asserting the public policy exception (Art. 279 Civil Procedure Law), including disputes concerning some specific Sino-foreign joint venture contracts.
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