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Comparative analysis of the limits to party autonomy under EU and US law


Marketed By :  VDM Verlag Dr. Müller   Sold By :  Kamal Books International  
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  • Product Description

This dissertation aims at offering a comparative study of the Rome Convention 1980 on the law applicable to contracts and the US law regarding the limits to the doctrine of freedom of choice of law by the parties. Particularly, the specific limits set by the mandatory rules of article 7 of the Rome Convention 1980, as well as those set by the public policy of the forum in article 16 will be analyzed and compared to the relevant provisions of the US law entailed in paragraphs 187(2) (b) of the Restatement Second and 1-105 of the Uniform Commercial Code. Finally, Rome I, a Regulation proposed by the European Commission to replace the Rome Convention 1980, will be examined in order to locate the positive and/or negative aspects of such an attempt, as well as the contribution that this development could bring about to the promotion of the integration of the Internal Market.

Product Specifications
SKU :COC21358
AuthorZabia Vernadaki
Number of Pages60
Publishing Year2010-01-10T00:00:00.000
Edition1 st
Book TypeInternational law
Country of ManufactureIndia
Product BrandVDM Verlag Dr. Müller
Product Packaging InfoBox
In The Box1 Piece
Product First Available On ClickOnCare.com2015-07-28 00:00:00