Conflict of Laws

This text provides an in-depth sophisticated coverage of the choice-of-law part conflicts law (or private international law) in torts, products liability, contracts, forum-selection and arbitration clauses, insurance, statutes of limitation, domestic relations, property, marital property, and successions. It also covers the constitutional framework and conflicts between federal law and foreign law and explains the doctrinal and methodological foundations of choice of law and then focuses on its actual practice, examining not only what courts say but also what they do.

This book offers a contractual framework for the regulation of party autonomy in choice of law. The party autonomy rule is the cornerstone of any modern system of choice of law; embodying as it does the freedom enjoyed by parties to a cross-border legal relationship to agree on the law applicable to it.

This book compares the Hague Principles on Choice of Law in International Commercial Contracts (2015) with national, regional, supranational, and international rules on choice of law around the world in order to chronicle the divergent approaches which exist today.

This title chronicles, documents, and celebrates the massive country-by-country codification of Private International Law (PrIL) or Conflict of Laws that has taken place from 1962-2012. The book provides a comparison and discussion of these codifications and conventions.

This text takes a "solutions to obstacles" approach, examining the existing jurisdiction and choice of law rules and proposes the interpretation of those rules to the digital age. It discusses the need of the modernization and harmonization of private international law, compares current legislative frameworks in the EU, US, China, and suggests a series of ways to remove the obstacles of the determination of Internet jurisdiction and choice of law for cross-border electronic B2B and B2C contracts.