THE RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS ON INTERNATIONAL COMMERCIAL ARBITRAL AWARDS

Kapitel in diesem Buch

1. Frontmatter I
2. TABLE OF CONTENTS VII
3. FOREWORD XI
4. ABBREVIATIONS XIII
5. DOCTRINE
6. FOR BETTER OR FOR WORSE: THE EUROPANIZATION OF INTERNATIONAL DIVORCE LAW 1
7. CHINESE PRIVATE INTERNATIONAL LAW STATUTE OF 28 OCTOBER 2010 27
8. THE RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS ON INTERNATIONAL COMMERCIAL ARBITRAL AWARDS 43
9. CHOICE OF LAW AND OVERRIDING MANDATORY RULES IN INTERNATIONAL CONTRACTS AFTER ROME I 67
10. RECENT DEVELOPMENTS IN U.S. CONFLICTS OF LAWS
11. THE EMERGENCE OF QUASI RULES IN U.S. CONFLICTS LAW 93
12. U.S. IMPLEMENTATION VEL NON OF THE 2005 HAGUE CONVENTION ON CHOICE OF COURT AGREEMENTS 107
13. MORRISON V. NATIONAL AUSTRALIA BANK: IMPLICATIONS FOR GLOBAL SECURITIES CLASS ACTIONS 123
14. A GUIDE TO UNITED STATES CASE LAW UNDER THE HAGUE CONVENTION ON THE CIVIL ASPECTS OF INTERNATIONAL CHILD ABDUCTION 139
15. RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS IN THE UNITED STATES 179
16. CODIFYING CHOICE OF LAW FOR TORT CONFLICTS: THE OREGON EXPERIENCE IN COMPARATIVE PERSPECTIVE 201
17. THE REVISION OF THE BRUSSELS I REGULATION
18. SURVEYING THE PROPOSED BRUSSELS I BIS REGULATION – SOLID FOUNDATIONS BUT RENOVATION NEEDED 247
19. WHAT SHOULD BE DONE ABOUT JURISDICTION AGREEMENTS? 311
20. APPLICATION OF THE BRUSSELS I REGULATION TO EXTERNAL SITUATIONS: FROM STUDIES CARRIED OUT BY THE EUROPEAN GROUP FOR PRIVATE INTERNATIONAL LAW (EGPIL/GEDIP) TO THE PROPOSAL FOR THE REVISION OF THE REGULATION 333
21. ABOLITION OF EXEQUATUR: PROBLEMS AND SOLUTIONS. MUTUAL RECOGNITION, MUTUAL TRUST AND RECOGNITION OF FOREIGN JUDGMENTS: TOO MANY WORDS IN THE SEA 351
22. CHOICE-OF-COURT AGREEMENTS: BREACH AND DAMAGES WITHIN THE BRUSSELS I REGIME 377
23. JURISDICTION OVER JURISDICTION AND CHOICE OF COURT AGREEMENTS: VIEWS ON THE HAGUE CONVENTION OF 2005 AND IMPLICATIONS FOR THE EUROPEAN REGIME 399
24. NEWS FROM THE HAGUE
25. THE HAGUE CONFERENCE ON PRIVATE INTERNATIONAL LAW: WORK IN PROGRESS (2008-2010) 419
26. NATIONAL REPORTS
27. THE IMPLEMENTATION OF THE REVISED LUGANO CONVENTION IN SWISS PROCEDURAL LAW 435
28. THE LAW APPLICABLE TO TECHNOLOGY TRANSFER CONTRACTS AND EGYPTIAN CONFLICT OF LAWS: A TRIUMPH OF NATIONALISM OVER INTERNATIONALISM? 457
29. PARTY AUTONOMY IN NORWEGIAN INTERNATIONAL MATRIMONIAL PROPERTY LAW AND SUCCESSION LAW 483
30. COMMON LAW INNOVATIONS IN PROVING FOREIGN LAW 493
31. AN OVERVIEW OF THE PRIVATE INTERNATIONAL LAW OF IRAN: THEORY AND PRACTICE 503
32. CONFLICT OF LAWS, CONFLICT OF MORES AND EXTERNAL PUBLIC POLICY IN ISRAEL: REGISTRATION AND RECOGNITION OF FOREIGN DIVORCE DECREES – A MODERN CRITIQUE 531
33. COURT DECISIONS
34. WEBSITE ACCESSIBILITY AS A BASIS FOR JURISDICTION UNDER ART. 15(1)(C) OF THE BRUSSELS I REGULATION: CASE NOTE ON THE ECJ JUDGMENTS PAMMER AND ALPENHOF 565
35. MODERN ART – THE ECJ’S LATEST SKETCHES OF Art. 5 No. 1 lit. b BRUSSELS I REGULATION 571
36. RESERVATION OF TITLE IN INSOLVENCY PROCEEDINGS: SOME REMARKS IN LIGHT OF THE GERMAN GRAPHICS JUDGMENT OF THE ECJ 587
37. RESISTING AMERICAN CLASS ACTIONS AT HOME: VIVENDI’S CRUSADE AGAINST U.S. IMPERIALISM 607
38. RECOGNITION IN SPAIN OF PARENTAGE CREATED BY SURROGATE MOTHERHOOD 619
39. FORUM
40. AN OLD ISSUE FROM A CURRENT PERSPECTIVE: AMERICAN AND EUROPEAN PRIVATE INTERNATIONAL LAW 639
41. MATERIALS
42. STATUTE ON THE APPLICATION OF LAWS TO CIVIL RELATIONSHIPS INVOLVING FOREIGN ELEMENTS OF THE PEOPLE’S REPUBLIC OF CHINA 669
43. INDEX 675