P. de Vries, Henry Keywords: United States of America | Conflict of laws | Private international law | Mots clefs: Etats-Unis d’Amérique | Droit interrégional | ABSTRACT Henry de Vries devotes his course to Recent Developments in Private International Law in the United States. After an introduction to the doctrines of conflict of laws, the author first discusses the issue of jurisdiction. The author then focuses on the issue of foreign judgments and on the issue of determining the choice of law. Henry de Vries consacre son cours aux développements récents intervenus dans le d…

E. Cheatham, Elliott Keywords: Common law | Conflict of laws | Mots clefs: Pays de Common law | Droit interrégional | ABSTRACT Elliott E. Cheatham begins his course with a presentation of the problems of conflict of laws. He examines the sources of rules of conflict of laws, and the relationship between federalism and conflict of laws. He then focuses on the analysis of the jurisdiction of the court of the forum, the question of foreign judgments, the protection of foreign-based legal interests, choice of law policie…

Reese, W. Keywords: United States of America | Conflict of laws | Mots clefs: Etats-Unis d'Amérique | Droit interrégional | ABSTRACT Professor Reese's course mainly focuses on the Restatement of Conflict of Laws Second. The restatements are documents containing several hundred Common law rules updated and commented by the American Law Institute. The author begins with a presentation of the restatements and the American Law Institute, different approaches to choice of law, and then presents the approach that Restatement second has policies of choice of law, contracts, and torts. Le c…

Kegel, Gerhard Keywords: United States of America | Conflict of laws | Mots clefs: Etats-Unis d'Amérique | Droit interrégional | ABSTRACT By speaking The Crisis of Conflict of Laws rather than revolution, Gerhard Klegel intends to show that on one hand serious criticisms could emanate from the despisers of conflict method, but also that, on the other hand, the foundations of the method of conflict still remain. The first part of the course is devoted to Governmental interests defended by Brainerd Currie. In the seco…

F. Cavers, David Keywords: United States of America | Conflict of laws | Mots clefs: Etats-Unis d’Amérique | Droit interrégional | ABSTRACT David Cavers devotes his general course on private international law on the situation in the United States (in 1970). He begins the course by presenting a legal system of the United States and its private international law. He then presents some persistent conceptual problems, and new approaches emerging in international law to the choice of tort law. He examines three clusters o…

M. North, Peter Keywords: United States of America | Family law | Conflict of laws | Private international law | Mots clefs: Etats-Unis d’Amérique | Droit interrégional | Droit de la famille | ABSTRACT In this course devoted to Development of Rules of Private International Law in the Field of Family Law, Peter North assigns several missions. He intends to show what developments have taken place in this field, why they have intervened in the field, what their effects have been, and what their future will be. He concentrates mainl…

K. Juenger, Friedrich Keywords: United States of America | Conflict of laws | Private international law | Mots clefs: Etats-Unis d’Amérique | Droit interrégional | ABSTRACT Noting the lack of consensus on the purposes and methods of conflict of laws, Fridrich Juenger, Professor at the University of California at Davis, suggests to focus in his course on events for which public international law must find a solution in order to avoid the constant danger that threatens the subject, that of becoming a mere academic game. Th…

Hay, Peter Keywords: United States of America | Conflict of laws | Europe | Private international law | Mots clefs: Etats-Unis d'Amérique | Droit interrégional | Droit international privé | Europe | ABSTRACT Peter Hay, Professor at the University of Illinois at Urbana-Champaign, emphasizes in the introduction to his course that a contradiction between the need for flexibility (to avoid an unfair decision) and the need for legal certainty cannot be resolved. It is the natural consequence of the difference between the development…

E. Herzog, Peter Keywords: United States of America | Conflict of laws | Constitutional law | Common law | Civil law | Mots clefs: Etats-Unis d'Amérique | Droit interrégional | Droit constitutionnel | Pays de Common law | Droit civil | ABSTRACT The point of this class is to understand the manner in which constitutional rules impact the choice of law depending on the countries. This study starts with a casuistic understanding of the position of United States, followed by Canada and Australia, as they are federal countries under common la…

Brilmayer, Lea Keywords: United States of America | Conflict of laws | Mots clefs: Etats-Unis d'Amérique | Droit interrégional | ABSTRACT Lea Brilmayer, Professor at New York University, devotes this course to the American choice of law theory, and more particularly to the role of substantive policies with regard to the formation and application of choice of law rules. Professor Brilmayer is particularly interested in the system of legal realism. The general introduction to her course is dedicated to the problem of …

C. Symeonides, Symeon Keywords: United States of America | Conflict of laws | Mots clefs: Etats-Unis d’Amérique | Droit interrégional | ABSTRACT Symeon Symeonides, Dean of devotes this course to a phenomenon known as a "revolution" in private international law in the United States, which more precisely relates to the law of conflicts of law. Symeonides studies the historic background of this phenomenon, but also looks towards the future to try to discover what the next step in the evolution of American conflicts law …

Meeusen, Johan Keywords: Equality | Human rights | Conflict of laws | Private international law | Mots clefs: ABSTRACT The impact of the nondiscrimination principle has been experienced in private international law after the Second World War. In this course, Johan Meeusen attempts to draw a contemporary view on the interaction between private international law and nondiscrimination, taking into account a specific perspective of the European Union and the Europeanization of private international law and to focus on…

Talpis, Jeffrey Keywords: Property | Estate | Law of succession | Law of property | Conflict of laws | Private international law | Common law | Civil law countries | Mots clefs: ABSTRACT The Professor first talks about the various instruments used to transfer property at death by succession, as well as the main characteristics and categories of successions. In a second part, is discussed the law used in known succession substitutes, as well as other new approaches used. Third, the choice of law rules is reviewed, in addition to…

Gannagé, Léna Keywords: Culture | Cultural diversity | Private international law | Conflict of laws | Pluralism | Mots clefs: ABSTRACT Private international law shows men and women from all walks of life every day, forming family relationships at the borders of legal orders of different cultures. The pluralism of family models prevailing in Europe is opposed to the hegemonism of a single-family model in Southern Mediterranean countries. In this course, Léna Gannagé describes the failure of the methods of private int…

Opertti Badán, Didier Keywords: Conflict of laws | Private international law | Unification of law | Mots clefs: ABSTRACT Didier Opertti Badán presented this course on the conflict of laws and uniform law in contemporary private international law at the 2012 inaugural conference. According to the author, the conflict of laws and jurisdictions are two autonomous legal categories that require a specific approach and respective technical solutions. He does so without denying the link that exists between them, which ca…

Weizuo, Chen Keywords: China | Private international law | Conflict of laws | Codification | Mots clefs: ABSTRACT In this course, Chen Weizuo examines some general and special issues of the new codification of Chinese private international law and focuses on China's new private international law. The author discusses the need for codification of the rules of law because, historically, China has had a tradition of written law. He focuses on the symposia, meetings, and doctrinal debates on the codification of Chine…

Basedow, Jürgen Keywords: Private international law | Conflict of laws | Development of international law | Globalization | Mots clefs: ABSTRACT This course looks into private international law from a new perceptive, by first focusing on the actor of international areas, private as public and what are their common point. The goal is to understand how closed nation-States, by globalization, showed an evolution leading to open society. After that, different form of private ordering intended to reduce the risk of inter…

Patrick Glenn, H. Keywords: Conflict of laws | Private international law | Mots clefs: ABSTRACT In this course, H. Patrick Glenn examines the so-called classical logic of private international law and reflects on the consequences of logic for private international law. He discusses the history of conflict of laws and the history of the conciliation of laws. The author discusses the conflict of laws and rules of private international law and examines the decline in the role of the rules. He continues with a not…

Kronke, Herbert Keywords: International commercial law | Conflict of laws | Private international law | Unification of law | Mots clefs: ABSTRACT This inaugural lecture is about institutional co-operation in transnational commercial law and conflict of law. A short overview of the history of distrust of conflict of laws showcases a cause leading to the promotion of transnational commercial law. The course offers then a definition of transnational commercial law, before giving examples of complementarity and co-operat…

Kono, Toshiyuki Keywords: Private international law | Conflict of laws | Choice of law | Law and economics | Unification of law | Effectiveness | Intellectual property | International insolvency law | Mots clefs: ABSTRACT As mentioned in the course, “efficiency is a corollary normative criterion which lies at the heart of law and economics approach.” The efficiency criterion is put into the context of conflict resolution, with a traditional approach including the choice of law revolution which took place in the twentieth century.…