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Codifying Choice of Law Around the World : an International Comparative Analysis

Author: Symeon Symeonides
Publisher: New York : Oxford University Press, USA, ©2014.
Edition/Format:   eBook : Document : EnglishView all editions and formats
Database:WorldCat
Summary:
Codifying Choice of Law Around the World chronicles, documents, and celebrates the extraordinary, massive codification of Private International Law (PrIL), or Conflict of Laws that has taken place in the last 50 years, from 1962-2012. During this period, the world has witnessed the adoption of nearly 200 PrIL codifications, EU Regulations, and international conventions--more than in all preceding years since the  Read more...
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Genre/Form: Electronic books
Additional Physical Format: Print version:
Material Type: Document, Internet resource
Document Type: Internet Resource, Computer File
All Authors / Contributors: Symeon Symeonides
ISBN: 9780199360857 0199360855
OCLC Number: 875635717
Description: 1 online resource : illustrations
Contents: Cover; Codifying Choice of Law Around the World; Copyright; Summary Table of Contents; Detailed Table of Contents; List of Charts; List of Figures; List of Maps; List of Tables; Foreword; Preface; Abbreviations; List of Choice-of-Law Codifications; List of EU Regulations (and Conventions); List of International Conventions; 1 Introduction; I. Introduction; II. National or Sub-national Choice-of-Law Codifications; A. The First Generation; B. The Second Generation; 1. Chronological List; 2. The Numbers; 3. Geographical Distribution; 4. Placement, Length, and Scope. III. European Union Conventions and RegulationsIV. International Choice-of-Law Conventions; V. Sorting the Data; VI. This Book; A. National Reports; B.A Road Map; 2 Law Governing Tort Conflicts; I. Introduction; II. The American Experience in Tort Conflicts; A. The American Choice-of-Law Revolution; B. Differentiating between Conduct-Regulation and Loss-Distribution; C. Summarizing the Results of the Case Law; 1. Common-Domicile Cases; 2. Split-Domicile Intra-state Torts; 3. Split-Domicile Cross-Border Torts; 4. Other Tort Conflicts and Products Liability; 5. Summary. III. The Lex Loci Delicti Rule in the Codifications of the Last 50 YearsA. General Inventory; B. The Lex Loci Still Rules; C. Defining the Locus Delicti in Cross-Border Torts: The Favor Laesi Principle; 1. Express Favor Laesi Rule; 2. Implied Favor Laesi; 3. Discretionary Favor Laesi; 4. Partial Favor Laesi; 5. Summary and Comparison; IV. Exceptions to the Lex Loci Delicti Rule; A. Precursors; B. The Closer-Connection Exception; 1. Closer Connection without Specific Examples; 2. Closer Connection with Examples. 3. Closer Connection as an Exception from Both the Lex Loci and the Parties' Common Law4. Common Party Affiliation as the Sole Exception; C. The Common Domicile Exception or Rule; 1. The Common Affiliation; 2. The Various Versions of the Common-Domicile Rule; a. Express Bilateral Rule; b. Implied Common-Domicile Rule; c. Unilateral Common-Domicile Rule; d. Summary and Comparison; D. Parties Domiciled in States with the Same Law; E. The Preexisting Relationship Exception; F. The Double Actionability Rule; G. Other Unilateral Exceptions in Favor of the Lex Fori; V. Rules of "Conduct and Safety." VI. Summary and Critique of the ExceptionsVII. Products Liability; A. Contacts-Based Rules; B. Favor Laesi Rules; VIII. Special Rules for Other Torts; IX. Party Autonomy; A. Post-Dispute Agreements; B. Pre-Dispute Agreements; X. Interim Conclusions; 3 Party Autonomy in Contract Conflicts; I. Party Autonomy: Ancient Origins and Modern Triumph; II. The Parameters of Party Autonomy; A. Internationality; B. Connection with Chosen State; 1. Required for All Contracts; 2. Required for Some Contracts; 3. Not Required; III. The Modalities of the Choice-of-Law Agreement; A. Mode of Expression.
Responsibility: Symeon C. Symeonides.

Abstract:

Codifying Choice of Law Around the World chronicles, documents, and celebrates the extraordinary, massive codification of Private International Law (PrIL), or Conflict of Laws that has taken place in the last 50 years, from 1962-2012. During this period, the world has witnessed the adoption of nearly 200 PrIL codifications, EU Regulations, and international conventions--more than in all preceding years since the inception of PrIL. This book provides a horizontal comparison and discussion of these codifications and conventions, first by comparing the way they resolve tort and contract conflict.
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