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Review of: PP Penasthika, Unravelling Choice of Law in International Commercial Contracts: Indonesia as an Illustrative Case Study (The Hague: Eleven Publishers 2022)

Conflict of Laws

Very recently, Indonesian private international law has attracted significant scholarship in the English language. [1] 1] Dr Penasthika’s monograph (‘the monograph’) [2] is one such work that deserves attention for its compelling and comprehensive account of choice of law in international commercial contracts in Indonesia.

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Lex & Forum 4/2021: A special on the 2019 Hague Convention on the Recognition of Foreign Judgments

Conflict of Laws

Professor Kerameus started his academic career at the Law School of the Aristotle University of Thessaloniki, in his home town, and completed his career at the University of Athens. He taught Civil Procedure, Comparative and International Procedural Law in Greek and other leading Universities abroad.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2021: Abstracts

Conflict of Laws

Thirdly, by considering the impact on the UK’s and the EU’s relationships with third countries, with particular reference to the 2007 Lugano Convention and Hague Choice of Court Convention. The principal focus will be on questions of jurisdiction, the recognition and enforcement of judgments and choice of law for contract and tort.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 4/2021: Abstracts

Conflict of Laws

Supreme Court decision in March 2021 in Ford vs. Montana now permits the exercise of specific jurisdiction when the claim arises out of or is (sufficiently) “related” to the defendant’s in-state contacts and activities. This comment raises the question whether the decision reduces or in effect continues the previous uncertainty.

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China Adopts Restrictive Theory of Foreign State Immunity

Conflict of Laws

To determine whether an act is commercial, “a PRC court shall undertake an overall consideration of the act’s nature and purpose.” Convention, the FSIL deals separately with employment contracts (Article 8) and intellectual property cases (Article 11). It is unclear if Chinese courts applying the FSIL will reach the same conclusion.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 5/2022: Abstracts

Conflict of Laws

Prior to the Rome Regulations, the conflict-of-law judgments on those “contracts with protective effect in favour of third parties” differed between German and Austrian courts. It points out that the Regulation Rome I covers only obligations that would not exist without the contract.

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A call for the wider study of Private International Law in Africa: A Review of Private International Law In Nigeria

Conflict of Laws

Writing on the importance of a private international law system that responds to the interests of Africa, Dr Okoli observed that with growing international trade with Africa comes an inevitable rise in disputes among contracting parties conducting trade on the continent. [4]

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