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RCD Holdings Ltd v LT Game International (Australia) Ltd: Foreign jurisdiction clauses and COVID-19

Conflict of Laws

In 2013, the plaintiffs, ePayment Solutions Pty Ltd (EPS) and RCD Holdings Ltd (RCD) concluded a written contract with the defendant, LT Game International (Australia) Ltd (LT) about the development and installation of a computer betting game. LT is a company incorporated in the Virgin Islands and registered in Australia as a foreign company.

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Anti-enforcement injunction granted by the New Zealand court

Conflict of Laws

For litigants embroiled in cross-border litigation, the anti-suit injunction has become a staple in the conflict of laws arsenal of common law courts. Kea alleges that the US default judgment is based on fabricated claims intended to defraud Kea.

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Application of Singapore’s new rules on service out of jurisdiction: Three Arrows Capital and NW Corp

Conflict of Laws

4] As Three Arrows illustrates though, old habits die hard and the limits of the ‘non-exhaustive’ nature of the jurisdictional gateways remains to be tested by litigants. 2] For step (a), the previous Order 11 gateways have been transcribed as a non-exhaustive list of factors. [3]

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Choice of Law in the American Courts in 2023

Conflict of Laws

Meanwhile the Fifth Circuit enforced a forum selection clause in an insurance contract choosing British Virgin Island courts despite evidence that the claims stood little chance in those courts. Extraterritoriality The Supreme Court decided two important extraterritoriality cases.

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