Volume XVIII Yearbook of Private International Law Vol. XVIII - 2016/2017

Book

Volume XVIII Yearbook of Private International Law Vol. XVIII - 2016/2017

Edited by: Andrea Bonomi and Gian Paolo Romano

Part of the multi-volume work

Yearbook of Private International Law

Language: English

Published/Copyright: 2018

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Topics

Law International Law, Foreign Law, Comparative Law International Law, Foreign Law, Comparative Law, other

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Frontmatter
i

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TABLE OF CONTENTS
vi

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Foreword
viii

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Abbreviations
x

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Doctrine
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The Lex Situs in the Law of Movables: A Swiss Cheese
1
Jurgen Basedow

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Distance Torts: the Mines de Potasse Decision Forty Years on
19
Carrascosa González Javier

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Foreign Same-Sex Marriages Before Commonwealth African Courts
39
Richard Frimpong Oppong and Solomon Amoateng

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Escape Clauses and Legal Certainty in Private International Law
61
Monika Pauknerová

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Protected Parties in European and American Conflict of Laws: A Comparative Analysis of Individual Employment Contracts
83
Jutta Gangsted and Geert Van Calster

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Recent Developments in the United States
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Jurisdiction in the Fourth Restatement of Foreign Relations Law
143
William S. Dodge

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Recent Developments in U.S. Law on Foreign Sovereign Immunity
171
David P. Stewart

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RJR Nabisco v. European Community and the Reach of U.S. Law
195
Aaron D. Simowitz

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Comity: the American Development of a Transnational Concept
211
Thomas Schultz and Niccolò Ridi

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The Speech Act and the Enforcement of Foreign Libel Judgments in the United States
245
John F. Coyle

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Environmental Cross-Border Torts
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Environmental Damages Caused by Transnational Groups: Access to Justice
259
Laura García Álvarez

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Cross-Border Environmental Damage in Conflict of Laws
289
Aurélie Planas

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National Reports
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Recognition or Non-Recognition of Foreign Civil Marriages in Israel
321
Yitshak Cohen

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An Overview of Vietnamese Private International Law
341
Ho Huong Pham and Ngoc Bich Hoang

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Matters of Succession under Turkish Private International Law
371
Ceyda Süral

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International Lis Pendens as a Contemporary Problem of Turkish International Civil Procedure
393
Gülüm Bayraktaroğlu Özçelik

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The Mauritian Supreme Court Reliance on French and British Laws to Resolve Private International Law Disputes
423
Jamil Ddamulira Mujuzi

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Court Decisions
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The EU Forum Non Conveniens Rule in Child Care Proceedings Cases Involving Public Bodies
431
Gilles Cuniberti and Céline Camara

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Surrogacy Abroad, Recognition (or Non-Recognition?) in Switzerland: A Painful Dilemma
441
Elodie Spahni

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Forum
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The Law Applicable to Intermediated Securities; Beyond PRIMA and The Hague Securities Convention
467
Alkaios-Panagiotis Sivitanidis

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Third Party and Contract in the Conflict of Laws
511
Sarah Laval

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The Role of Independent Administrative Authorities in Global Governance
543
Réka Ágnes Papp

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The CMR 1956 Convention: Some Specific Issues from a Private International Law Perspective
569
Unai Belintxon Martín

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Index
591

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Publishing information

Pages and Images/Illustrations in book

eBook published on:

October 26, 2017

eBook ISBN:

9783504385637

Pages and Images/Illustrations in book

Main content:

608

https://doi.org/10.9785/9783504385637

eBook ISBN: 9783504385637

Keywords for this book

internationales Privatrecht (IPR); europäisches Privatrecht; nationale Rechtsordnungen; Jahrbuch

Volume XVIII Yearbook of Private International Law Vol. XVIII - 2016/2017

Overview

Topics

Table of contents

Frontmatter

TABLE OF CONTENTS

Foreword

Abbreviations

The Lex Situs in the Law of Movables: A Swiss Cheese

Distance Torts: the Mines de Potasse Decision Forty Years on

Foreign Same-Sex Marriages Before Commonwealth African Courts

Escape Clauses and Legal Certainty in Private International Law

Protected Parties in European and American Conflict of Laws: A Comparative Analysis of Individual Employment Contracts

Jurisdiction in the Fourth Restatement of Foreign Relations Law

Recent Developments in U.S. Law on Foreign Sovereign Immunity

RJR Nabisco v. European Community and the Reach of U.S. Law

Comity: the American Development of a Transnational Concept

The Speech Act and the Enforcement of Foreign Libel Judgments in the United States

Environmental Damages Caused by Transnational Groups: Access to Justice

Cross-Border Environmental Damage in Conflict of Laws

Recognition or Non-Recognition of Foreign Civil Marriages in Israel

An Overview of Vietnamese Private International Law

Matters of Succession under Turkish Private International Law

International Lis Pendens as a Contemporary Problem of Turkish International Civil Procedure

The Mauritian Supreme Court Reliance on French and British Laws to Resolve Private International Law Disputes

The EU Forum Non Conveniens Rule in Child Care Proceedings Cases Involving Public Bodies

Surrogacy Abroad, Recognition (or Non-Recognition?) in Switzerland: A Painful Dilemma

The Law Applicable to Intermediated Securities; Beyond PRIMA and The Hague Securities Convention

Third Party and Contract in the Conflict of Laws

The Role of Independent Administrative Authorities in Global Governance

The CMR 1956 Convention: Some Specific Issues from a Private International Law Perspective

Index

Bibliographic data