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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 2/2021: Abstracts

Conflict of Laws

The Higher Regional Court (OLG) Saarbrücken had to decide upon appeal by a German-based limited liability company (GmbH) against a French motor vehicle liability insurer on various questions of French indemnity law and its interaction with German procedural law.

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Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 6/2021: Abstracts

Conflict of Laws

The court held that the enforcement provision Article V (1) lit. Pursuant to this provision, the arbitration agreement is governed by the law chosen by the parties and, subsidiarily, the law of the seat. The rule has rightly been heavily criticized in the scientific literature. 13 (3) No.

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