... to choice of law issues—contractual agreement or determination by a court after a dispute arises—fit the research context well. We hosted a series of workshops with choice of law experts and research law and ethics experts to identify factors that are most crucial to account for in a future choice of law...

... light on this topic, we conducted interviews with experts in law, human research protections, and precision medicine research. Our goal was to better understand their experiences with choice of law issues, the effects of state law variation on research practices and stakeholder groups, and approaches...

... survey on the choice of law and its empirical relevance, the article investigates the market distortions to which parties are exposed through an international perspective and sheds light on the various measures and alternatives to tackle these failures. In conclusion, the article aims to elucidate what...

...This introductory chapter begins with a discussion of the origin of the terms “conflict of laws” and “private international Law” and the different assumptions underlying them, and continues with a description of the three parts of conflicts law: jurisdiction, choice of law, and recognition...

... on whether or not the contract also contains a choice-of-law clause. After describing the divisions among courts on this question, it takes a position on the proper answer and explains why. It concludes with a discussion of the doctrine of separability or severability of the forum selection clause. Part II...

...Chapter 4 examines the law applicable to sovereign domestic bonds in the absence of a choice of law provision. It is commonly believed that the domestic debt is necessarily governed by the law of the sovereign. The chapter challenges that premise by arguing that the law of the creditor should apply...

... bonds which this time contained a choice of English law. As a matter of English law, the 142 inclusion of an English choice of law clause would in future insulate the bonds from unilateral changes of law by the Greek parliament. ⁴ Thus, in National Bank of Greece and Athens v...

... will examine the obligation to repay and the attacks mounted against it. Section II will consider the defences that a sovereign debtor can raise against the recovery of the payments under the bonds. International Commercial Litigation Choice of law Choice of court and jurisdictional agreements...

... of court and choice of law agreements. A.7.46 As the criterion that the agreement shall be freely negotiated does not provide any relevant additional protection for the parties already pursuing commercial...

... processes. Host state law Calvo clause Choice of law Investor Nationality of investor Sovereignty Immunity from jurisdiction, states Act of state doctrine Diplomatic immunity Investment is by definition a risky enterprise, and foreign investment particularly so. History is replete with government...

... to place. This requires the identification and knowledge of the national law that should govern an international negotiable instrument. This book offers a comprehensive and thorough analysis of the choice-of-law rules applicable to negotiable instruments. It argues that the complex case of international...

...This chapter addresses two trends developing within the choice-of-law doctrine: the relaxation of the ‘foreign element’ requirement and the advances of the party autonomy principle. Chapter III has pointed to the advancing phenomenon of the increasing rate of cross-border commerce, electronic...

...This book marries two fields of law: negotiable instruments and choice-of-law. Bills of exchange, cheques, and promissory notes are the main classical negotiable instruments. For centuries, these have played a vital role in the smooth operation of domestic and international commerce. The rapid...

...Burden of proof Admissibility Witnesses Issue and cause of action estoppel Promissory estoppel Scope of the law applicable under the Rome II Regulation Rome I Regulation and choice of law Overriding mandatory rules 7.01 The law of evidence is another area which has long been considered...

...Statutes of limitation Overriding mandatory rules Public policy Rome Convention Rome I Regulation and choice of law Jurisdiction and the English courts Limitations on jurisdiction Scope of the law applicable under the Rome II Regulation ¹ Pederson v Young...

... of contract Breach of contract UN Sales Convention and choice of law Damages Goods THE STATES PARTIES TO THIS CONVENTION, BEARING IN MIND the broad objectives in the resolutions adopted by the sixth special session of the General Assembly of the United Nations on the establishment of a New International...