Volume XII 2010: Volume XII (2010)

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Volume XII 2010

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Part of the multi-volume work

Yearbook of Private International Law

Language: English

Published/Copyright: 2011

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About this book

The current rich volume of the "Yearbook of Private International Law" includes a special section on actual issues on conflict of laws and jurisdictions in the United States. Another special section is devoted to the revision of the Brussels I Regulation, in particular after the recent proposal by the European Commission. National reports and court decisions complete the book.

Recent highlights include:

the new Chinese Statute on Private International Law
the Rome III Regulation on the Law Applicable to Separation and Divorce
the recent CJUE decisions on jurisdiction in contractual disputes, in particular in the case of e-commerce
the law applicable to the actio pauliana
national reports from Egypt, Iran, Israel and Norway

Topics

Law Law, other

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Frontmatter
I

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TABLE OF CONTENTS
VII

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FOREWORD
XI
Andrea Bonomi and Gian Paolo Romano

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ABBREVIATIONS
XIII

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DOCTRINE
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FOR BETTER OR FOR WORSE: THE EUROPANIZATION OF INTERNATIONAL DIVORCE LAW
1
Katharina BOELE-WOELKI

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CHINESE PRIVATE INTERNATIONAL LAW STATUTE OF 28 OCTOBER 2010
27
CHEN Weizuo

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THE RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS ON INTERNATIONAL COMMERCIAL ARBITRAL AWARDS
43
Talia EINHORN

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CHOICE OF LAW AND OVERRIDING MANDATORY RULES IN INTERNATIONAL CONTRACTS AFTER ROME I
67
Sixto SÁNCHEZ LORENZO

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RECENT DEVELOPMENTS IN U.S. CONFLICTS OF LAWS
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THE EMERGENCE OF QUASI RULES IN U.S. CONFLICTS LAW
93
Patrick J. BORCHERS

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U.S. IMPLEMENTATION VEL NON OF THE 2005 HAGUE CONVENTION ON CHOICE OF COURT AGREEMENTS
107
Ronald A. BRAND

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MORRISON V. NATIONAL AUSTRALIA BANK: IMPLICATIONS FOR GLOBAL SECURITIES CLASS ACTIONS
123
Linda J. SILBERMAN

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A GUIDE TO UNITED STATES CASE LAW UNDER THE HAGUE CONVENTION ON THE CIVIL ASPECTS OF INTERNATIONAL CHILD ABDUCTION
139
Robert G. SPECTOR

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RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS IN THE UNITED STATES
179
David P. STEWART

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CODIFYING CHOICE OF LAW FOR TORT CONFLICTS: THE OREGON EXPERIENCE IN COMPARATIVE PERSPECTIVE
201
Symeon C. SYMEONIDES

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THE REVISION OF THE BRUSSELS I REGULATION
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SURVEYING THE PROPOSED BRUSSELS I BIS REGULATION – SOLID FOUNDATIONS BUT RENOVATION NEEDED
247
Andrew DICKINSON

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WHAT SHOULD BE DONE ABOUT JURISDICTION AGREEMENTS?
311
Adrian BRIGGS

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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
Alegría BORRÁS

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ABOLITION OF EXEQUATUR: PROBLEMS AND SOLUTIONS. MUTUAL RECOGNITION, MUTUAL TRUST AND RECOGNITION OF FOREIGN JUDGMENTS: TOO MANY WORDS IN THE SEA
351
Rafael ARENAS GARCÍA

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CHOICE-OF-COURT AGREEMENTS: BREACH AND DAMAGES WITHIN THE BRUSSELS I REGIME
377
Sara SÁNCHEZ FERNÁNDEZ

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JURISDICTION OVER JURISDICTION AND CHOICE OF COURT AGREEMENTS: VIEWS ON THE HAGUE CONVENTION OF 2005 AND IMPLICATIONS FOR THE EUROPEAN REGIME
399
Diana SANCHO VILLA

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NEWS FROM THE HAGUE
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THE HAGUE CONFERENCE ON PRIVATE INTERNATIONAL LAW: WORK IN PROGRESS (2008-2010)
419
Hans VAN LOON

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NATIONAL REPORTS
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THE IMPLEMENTATION OF THE REVISED LUGANO CONVENTION IN SWISS PROCEDURAL LAW
435
Rodrigo RODRIGUEZ and Alexander R. MARKUS

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THE LAW APPLICABLE TO TECHNOLOGY TRANSFER CONTRACTS AND EGYPTIAN CONFLICT OF LAWS: A TRIUMPH OF NATIONALISM OVER INTERNATIONALISM?
457
Mohamed S. ABDEL WAHAB

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PARTY AUTONOMY IN NORWEGIAN INTERNATIONAL MATRIMONIAL PROPERTY LAW AND SUCCESSION LAW
483
Torstein FRANTZEN

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COMMON LAW INNOVATIONS IN PROVING FOREIGN LAW
493
Tiong Min YEO

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AN OVERVIEW OF THE PRIVATE INTERNATIONAL LAW OF IRAN: THEORY AND PRACTICE
503
Seyed N. EBRAHIMI

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CONFLICT OF LAWS, CONFLICT OF MORES AND EXTERNAL PUBLIC POLICY IN ISRAEL: REGISTRATION AND RECOGNITION OF FOREIGN DIVORCE DECREES – A MODERN CRITIQUE
531
Adi CHEN

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COURT DECISIONS
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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
Michael BOGDAN

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MODERN ART – THE ECJ’S LATEST SKETCHES OF Art. 5 No. 1 lit. b BRUSSELS I REGULATION
571
Eva LEIN

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RESERVATION OF TITLE IN INSOLVENCY PROCEEDINGS: SOME REMARKS IN LIGHT OF THE GERMAN GRAPHICS JUDGMENT OF THE ECJ
587
Zeno CRESPI REGHIZZI

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RESISTING AMERICAN CLASS ACTIONS AT HOME: VIVENDI’S CRUSADE AGAINST U.S. IMPERIALISM
607
Gilles CUNIBERTI

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RECOGNITION IN SPAIN OF PARENTAGE CREATED BY SURROGATE MOTHERHOOD
619
Patricia OREJUDO PRIETO DE LOS MOZOS

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FORUM
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AN OLD ISSUE FROM A CURRENT PERSPECTIVE: AMERICAN AND EUROPEAN PRIVATE INTERNATIONAL LAW
639
Carmen AZCÁRRAGA MONZONÍS

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MATERIALS
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STATUTE ON THE APPLICATION OF LAWS TO CIVIL RELATIONSHIPS INVOLVING FOREIGN ELEMENTS OF THE PEOPLE’S REPUBLIC OF CHINA
669
CHEN Weizuo and Kevin M. MOORE

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INDEX
675

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Publishing information

Pages and Images/Illustrations in book

eBook published on:

November 14, 2011

eBook ISBN:

9783866539488

Pages and Images/Illustrations in book

Front matter:

14

Main content:

680

https://doi.org/10.1515/9783866539488

eBook ISBN: 9783866539488

Volume XII 2010

Overview

About this book

Topics

Table of contents

Frontmatter

TABLE OF CONTENTS

FOREWORD

ABBREVIATIONS

FOR BETTER OR FOR WORSE: THE EUROPANIZATION OF INTERNATIONAL DIVORCE LAW

CHINESE PRIVATE INTERNATIONAL LAW STATUTE OF 28 OCTOBER 2010

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

CHOICE OF LAW AND OVERRIDING MANDATORY RULES IN INTERNATIONAL CONTRACTS AFTER ROME I

THE EMERGENCE OF QUASI RULES IN U.S. CONFLICTS LAW

U.S. IMPLEMENTATION VEL NON OF THE 2005 HAGUE CONVENTION ON CHOICE OF COURT AGREEMENTS

MORRISON V. NATIONAL AUSTRALIA BANK: IMPLICATIONS FOR GLOBAL SECURITIES CLASS ACTIONS

A GUIDE TO UNITED STATES CASE LAW UNDER THE HAGUE CONVENTION ON THE CIVIL ASPECTS OF INTERNATIONAL CHILD ABDUCTION

RECOGNITION AND ENFORCEMENT OF FOREIGN JUDGMENTS IN THE UNITED STATES

CODIFYING CHOICE OF LAW FOR TORT CONFLICTS: THE OREGON EXPERIENCE IN COMPARATIVE PERSPECTIVE

SURVEYING THE PROPOSED BRUSSELS I BIS REGULATION – SOLID FOUNDATIONS BUT RENOVATION NEEDED

WHAT SHOULD BE DONE ABOUT JURISDICTION AGREEMENTS?

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

ABOLITION OF EXEQUATUR: PROBLEMS AND SOLUTIONS. MUTUAL RECOGNITION, MUTUAL TRUST AND RECOGNITION OF FOREIGN JUDGMENTS: TOO MANY WORDS IN THE SEA

CHOICE-OF-COURT AGREEMENTS: BREACH AND DAMAGES WITHIN THE BRUSSELS I REGIME

JURISDICTION OVER JURISDICTION AND CHOICE OF COURT AGREEMENTS: VIEWS ON THE HAGUE CONVENTION OF 2005 AND IMPLICATIONS FOR THE EUROPEAN REGIME

THE HAGUE CONFERENCE ON PRIVATE INTERNATIONAL LAW: WORK IN PROGRESS (2008-2010)

THE IMPLEMENTATION OF THE REVISED LUGANO CONVENTION IN SWISS PROCEDURAL LAW

THE LAW APPLICABLE TO TECHNOLOGY TRANSFER CONTRACTS AND EGYPTIAN CONFLICT OF LAWS: A TRIUMPH OF NATIONALISM OVER INTERNATIONALISM?

PARTY AUTONOMY IN NORWEGIAN INTERNATIONAL MATRIMONIAL PROPERTY LAW AND SUCCESSION LAW

COMMON LAW INNOVATIONS IN PROVING FOREIGN LAW

AN OVERVIEW OF THE PRIVATE INTERNATIONAL LAW OF IRAN: THEORY AND PRACTICE

CONFLICT OF LAWS, CONFLICT OF MORES AND EXTERNAL PUBLIC POLICY IN ISRAEL: REGISTRATION AND RECOGNITION OF FOREIGN DIVORCE DECREES – A MODERN CRITIQUE

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

MODERN ART – THE ECJ’S LATEST SKETCHES OF Art. 5 No. 1 lit. b BRUSSELS I REGULATION

RESERVATION OF TITLE IN INSOLVENCY PROCEEDINGS: SOME REMARKS IN LIGHT OF THE GERMAN GRAPHICS JUDGMENT OF THE ECJ

RESISTING AMERICAN CLASS ACTIONS AT HOME: VIVENDI’S CRUSADE AGAINST U.S. IMPERIALISM

RECOGNITION IN SPAIN OF PARENTAGE CREATED BY SURROGATE MOTHERHOOD

AN OLD ISSUE FROM A CURRENT PERSPECTIVE: AMERICAN AND EUROPEAN PRIVATE INTERNATIONAL LAW

STATUTE ON THE APPLICATION OF LAWS TO CIVIL RELATIONSHIPS INVOLVING FOREIGN ELEMENTS OF THE PEOPLE’S REPUBLIC OF CHINA

INDEX

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