This book explores the source and extent of the right of parties to an international contract to make appropriate arrangements for the determination of their legal relationship, primarily by selecting the applicable law, but also by selecting the judicial or arbitral forum. The book focuses on the legal systems of the United States, the Commonwealth jurisdictions and the civil law countries of western and central Europe. This fascinating analysis will be welcomed by practitioners and scholars alike.
This book explores the source and extent of the right of parties to an international contract to make appropriate arrangements for the determination o...
This book systematically examines claims for contribution and reimbursement in an international context. As such claims are often made in third party proceedings, particularly detailed analyses are given to the conflict-of-laws dimensions of third party procedure.
This book systematically examines claims for contribution and reimbursement in an international context. As such claims are often made in third party ...
This book analyzes the EU's recent moves towards harmonization of civil procedure and execution of judgments. It also offers a comparative survey of enforcement policies in representative European jurisdictions, including England, Germany, France, Sweden, and Spain. The volume will be of interest both to academics and to litigation specialists in practice.
This book analyzes the EU's recent moves towards harmonization of civil procedure and execution of judgments. It also offers a comparative survey of e...
This book provides a much-needed analysis of corporations in private international law. It discusses the principle of freedom of establishment and attempts to determine where a corporation has its "seat" for legal purposes.
This book provides a much-needed analysis of corporations in private international law. It discusses the principle of freedom of establishment and att...
Forum shopping in international litigation and arbitration is the product of the differences which exist in the procedural and substantive laws of countries throughout the world participating in an ever-more globalized economy.This book provides an in-depth study of the conditions for, motivations behind and techniques of forum shopping as well as possible defences against it. It will be of interest to practitioners, judges and academics throughout the common law world, the European Union and the United States.
Forum shopping in international litigation and arbitration is the product of the differences which exist in the procedural and substantive laws of cou...
The enforcement of patent rights raises complex, and, from a private international law perspective, unique difficulties. This book analyzes in detail both the European rules on jurisdiction (the Brussels Convention and its successors) and the choice of law rules as they apply to cross-border patent disputes, and will be essential reading for both intellectual property lawyers and international commercial litigation specialists.
The enforcement of patent rights raises complex, and, from a private international law perspective, unique difficulties. This book analyzes in detail ...
This book examines the problems of choice of law where transactions cross borders and involve shares or other securities of different nationalities. It considers dealings in securities under the traditional direct holding system and under the modern system of holding through intermediaries. Various theories and legislative reforms have been suggested in an attempt to resolve these two methods, and the book examines the extent to which they provide a viable solution.
This book examines the problems of choice of law where transactions cross borders and involve shares or other securities of different nationalities. I...