Choice of Law in UK Law
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Commercial Choice of Law in Context: Looking Beyond Rome
English courts are frequently criticised for their flexible approach to the finding of implied choice and the use of the escape clause in the context of the Rome I Regulation/Convention on the law ...
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THE IMPORTANCE OF CHOICE OF LAW AND FINALITY TO PvP, NETTING AND COLLATERAL ARRANGEMENTS
The authors argue that two of the significant legal issues that must be solved if cross‐border payment versus payment, netting and collateral arrangements are to achieve their full potential involv...
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The Territorial Scope of Employment Legislation and Choice of Law
Traditionally, the determination of the territorial scope of the statutory rights conferred by employment legislation forming part of English law has been regarded as an issue entirely disconnected...
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Choice of law clauses in customer agreements: NASD conduct rule 3110(f)(4)
Most account opening agreements used by US brokerage firms contain a standard predispute arbitration clause requiring customers to submit all disputes relating to the account to arbitration conduct...
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Choice of Law in Tort—Blending in with the Landscape of the Conflict of Laws?
The reformed choice of law in tort rules contained in the Private International Law (Miscellaneous Provisions) Act 1995 have proved a source of great controversy. This piece attempts to show that t...
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Equal Treatment on the Grounds of Movement and Union Choice-of-Law Rules under Article 81 TFEU
Union choice-of-law rules adopted pursuant to Article 81 TFEU aim to promote the exercise of the Treaty free movement rights by providing certainty over the applicable law and predictability of lit...
- CHOICE OF LAW PROVISIONS—A REJOINDER
- Accidents - Choice of Law and Jurisdiction
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Does a Choice of Law Bind a Claimant in a Direct Action? An Analysis in Relation to Insurance Contracts in a Maritime Law Context
This article examines the application of European Union rules on a choice of law in relation to direct action claims, with a focus on insurance contracts in a maritime setting. This is an important...
- LIMITATIONS IN CHOICE OF LAW PROVISIONS—A COMMENT
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