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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

The FSIL’s reciprocity clause is consistent with the emphasis on reciprocity that one finds in other provisions of Chinese law. As discussed further below, the addition of “rulings” (??) to Article 14(3) is significant because Chinese court decisions that recognize foreign judgments are considered “rulings.”

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Update: HCCH 2019 Judgments Convention Repository

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The 21-19 (available here ). 103-113.

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Update: HCCH 2019 Judgments Convention Repository

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The 21-19 (available here ). 103-113.

article thumbnail

Update: HCCH 2019 Judgments Convention Repository

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The 21-19 (available here ). 103-113.

article thumbnail

Update: HCCH 2019 Judgments Convention Repository

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The Zhang, Chunliang; Huang, Shan. “On

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Update: Repository HCCH 2019 Judgments Convention

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The 21-19 (available here ). 103-113.

article thumbnail

Update: HCCH 2019 Judgments Convention Repository

Conflict of Laws

The Recognition and Enforcement of Court Decisions Between the EU and Third States”, in Alexander Trunk, Nikitas Hatzimihail (eds.), EU Civil Procedure Law and Third Countries – Which Way Forward?, Martiny, Dieter. Baden-Baden 2021, pp 127-146. Codifying Comity: The Case for U.S. “The 21-19 (available here ). 103-113.