Jayme, Erik Keywords: Languages | Choice of law | Private international law | Mots clefs: ABSTRACT Language is an important element in private international law. As a connecting factor, it is an element of a person's identity, can be used in family and succession law, or to define the habitual character of a residence. The language also has a role to play in certain cases for the principle of nationality or in contracts where it can justify a tacit choice of law. The question of linguistic risk is also mentioned, in the case of languages not known by weak people. The laws on …

Boele-Woelki, Katharina Keywords: Party autonomy | Choice of law | International contracts | Private international law | International commercial arbitration | Trials | Mots clefs: A…

Blanca Noodt Taquela, María Keywords…

Frigo, Manlio Keywords: Cultural property | Cultural heritage | Choice of law | Restitution | Dispute resolution | Trials | Mots clefs: ABSTRACT This course is dedicated to the s…

M. De Boer, Th. Keywords: International commercial arbitration | …

Cachard, Olivier Keywords: Carriage of passengers and their luggage | Aircraft accidents | Private air law | International air law | Air transport | Unification of law…

…

…

Hayton, DavidHayton, David

Kohler, Christian Keywords: Will | Autonomy | Private international law | Choice of law | Mots clefs: ABSTRACT Since the beginning of the century, the autonomy of the will in private international law has been influenced by two opposing …

A. Brand, Ronald Keywords: Court settlements | Recognition and enforcement of foreign judgments | Jurisdiction | Choice of law | Forum shopping | Private international law | Mots clefs: ABSTRACT This class starts by considering the transaction planning tools, by comparing the rules that exist in the United States and the European Union. A description of the United States and European Union jurisdictions is given, followed by an explanation of their rules of recognition and enforcement of judgments. The lecture continues by considering the main issue at the intersection of private party and State interests: the party autonomy. A short historical overview is given, as well as the limits of the …

Briggs, Adrian Keywords: Private international law | Choice of law | International law of procedure | Comity | Mots clefs…

Boele-Woelki, Katharina Keywords: Family law | Private international law | Choice of law | Unification of law | Law of contracts | Model law | Legal principles | Conventions | Directives | International law and domestic law | Mots clefs: ABSTRACT Traditionally, conflict of law rules designate only national substantive law as the applicable law. Many unifying and harmonizing substantive law instruments of both States and non-State organizations, however, are designed specifically f…

Dogauchi, Masato Keywords: Japan | Private international law | Legal history | Choice of law | Mots clefs: Japon | Droit international privé | Histoire du droit | Choix de la loi applicable | ABSTRACT The course of Masato Dogauchi, Professor at Waseda University in Tokyo, has two objectives. One is to provide a brief introduction to choice-of-law rules in Japan. The other is to present a four-step analysis in choice-of-law rules. This method of analysis is considered applicable not only to Japanese rules but also to rule…

Jänterä-Jareborg, Maarit Keywords: Municipal courts | Foreign law | Choice of law | Private international law | Mots clefs: Juridiction nationale | Droit étranger | Choix de la loi applicable | Droit international privé | ABSTRACT In this course on comparative private international law, Professor Maarit Jänteä-Jareborg of the University of Uppsala tackles the question of the application of foreign law in national courts. In the…

M. De Boer, Th. Keywords: Choice of law | Private international law | Mots clefs: …

E. Nygh, Peter Keywords: Australia | Law of contracts | Choice of law | Private international law | Contracts | Tort | Mots clefs: Australie | Droit des obligations | Choix de la loi applicable | Droit international privé | Contrats | Quasi-contrats et quasi-délits | ABSTRACT This course by Peter E. Nygh, Professor at Bond University on Australia's Gold Coast, addresses the role played by the "reasonable expectations of the parties" in conflicts regarding laws of contract and tort. The reasonable expectations of the parties include first of …

Seyersted, Finn Keywords: International organizations | Non-State actoRelations | Choice of law | International civil servants | Individuals | Nongovernmental organizations | Mots clefs: Organisations internationales | Entités non-étatiques | Relations | Choix de la loi applicable | Fonctionnaires internationaux | Individus | Organisations non-gouvernementales | ABSTRACT According to Finn Seyersted, there exists a common law for international organizations at three levels of relationships: the internal level, the international level, and the…

Cansacchi, Giorgio Keywords: Choice of law | Private international law | Mots clefs: Choix de la loi applicable | Droit international privé | ABSTRACT Giorgio Cansacchi's course focuses particularly on the study of the choice of the substantive rule competent to settle a disputed situation, or an aspect of that situation, when the judge of forum is faced with a plurality of connecting circumstances enacted by his conflict rule. The author also focuses on the problem of adapting the substantive rule chosen in the order of the forum. Le cours de Giorgio Cansacchi se concentre particu…