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However, he found the most promising solution to lie at the heart of conflict of laws theory: substantive law consideration. Chikoc Barreda explained that this fragmentation leads to challenges for Private International Law. Brhin based this proposal on the rationale of Art.3(h) 3(h) DSA and Art.14(4)
The following analysis undertakes the attempt to clarify the key aspects from the perspective of German international private law. Eichel: Choice of Court Agreements and Rules of Interpretation in the Context of Tort or Anti-trust Claims. 1 Lugano Convention 2007 vis-à-vis claims in tort. 1 Brussels Ia Regulation/Art.
The principal focus will be on questions of jurisdiction, the recognition and enforcement of judgments and choice of law for contract and tort. Zwirlein-Forschner: Road Tolls in Conflict of Laws and International Jurisdiction – a Cross-Border Journey between the European Regulations. 20 EGBGB.
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