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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

Very recently, Indonesian private international law has attracted significant scholarship in the English language. [1] 1] Dr Penasthika’s monograph (‘the monograph’) [2] is one such work that deserves attention for its compelling and comprehensive account of choice of law in international commercial contracts in Indonesia.

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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. This is exemplified by the decisions of the Higher Regional Court of Cologne for the international service of process.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2022: Abstracts

Conflict of Laws

Wolfram: Achmea – neglecting of international public law – some afterthoughts. This contribution is not meant to assess the Achmea judgment of the European Court of Justice. The contribution concludes this is not generally the case under the Vienna Convention on the Law of Treaties. Heiderhoff/E.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2021: Abstracts

Conflict of Laws

Dickinson: Realignment of the Planets – Brexit and European Private International Law. Thirdly, by considering the impact on the UK’s and the EU’s relationships with third countries, with particular reference to the 2007 Lugano Convention and Hague Choice of Court Convention.

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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

Ayer Chair in Business Law and Martin Luther King Jr. Professor of Law at UC Davis School of Law. On September 1, 2023, the Standing Committee of the National People’s Congress promulgated the Foreign State Immunity Law of the People’s Republic of China (FSIL) (English translation here ). In 2005, China signed the U.N.

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

Conflict of Laws

After five years of application of the European Succession Regulation it is time to have a look at European court practice: The general connecting factor of habitual residence has somehow been addressed by the European Court of Justice (ECJ) in E.E. , 102 TFEU and/or national competition law rules. The long-awaited U.S.

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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

German civil procedural law allows for video hearings under section 128a (1) German Code of Civil Procedure. Things are cetainly more difficult when it comes to the taking of evidence. The Panel has done this only once so far, apparently within the scope of application of the EU Taking of Evidence Regulation.

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