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The Choice-Based Perspective of Choice-of-Law [PDF]
This article offers an innovative basis for the choice-of-law question: the Choice-Based Perspective (CBP). The main argument is that there exists an alternative rights-based understanding of choice-of-law to that which is presently known as the vested ...
Peari, Sagi
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Recovery of public authorities’ costs for pure environmental harm, ie harm that does not entail an economic loss on part of the authorities, is unlikely to be considered a ‘civil matter’ under Rome II – or the Judgments Regulation/Lugano Convention.
Henrik Bull
doaj +1 more source
No-Fault Insurance and the Conflict of Laws—An Interim Update [PDF]
In an article published in the Duke Law Journal in June of 1972, Professor Kozyris proposed a choice of law system for no-fault which would resolve in a novel way the confusion engendered by disparate state approaches to the problems of compensation and ...
Kozyris, P. John
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Limitations on Jurisdiction and Arbitration Agreements Based on Applicable Law and the Identity of the Carrier in Cargo Claim Disputes [PDF]
The article demonstrates through an analysis of the limitations on choice of forum or arbitration agreements following the invalidity of a choice of law clause included in a charter party and/or a bill of lading (B/L). It is equally difficult enforcing a
Echebarria Fernández, J.
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The State Whose Law is Selected
The ability of parties to a multistate contract to choose the law that governs their relationship, once controversial, is now almost universally accepted. So too are the conventional limits on that ability.
Kermit Roosevelt
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Characteristics of Party autonomy in a Transnational Electronic Consumer Contract
International contracts involving legal subjects between countries will affect the law chosen by the parties. Electronic contracts are different than conventional contracts in general.
Moh. Ali, Agus Yudha Hernoko
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Article 7 of Rome I contains the same rules on choice of law for insurance contracts as previously found in various insurance directives. The rules are technically very complicated.
Henrik Bull
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The impact of EU law on Norwegian private international law
Norway is not a EU member state, but is associated to the EU through the European Economic Area (EEA) Agreement. The EEA Agreement extends the single market to Norway, but does not cover the area of judicial cooperation.
Giuditta Cordero-Moss
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The European Court of Human Rights, whose jurisprudence is presented here, is not a court specialising in private international law. However it applies the norms deriving from the European Convention on Human Rights to applications by litigants ...
Patrick Kinsch
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Sensitivity of grounding line dynamics to the choice of the friction law
Basal slip accounts for a large part of the flow of ice streams draining ice from Antarctica and Greenland into the ocean. Therefore, an appropriate representation of basal slip in ice flow models is a prerequisite for accurate sea level rise projections.
J. Brondex+3 more
semanticscholar +1 more source