Chapters in this book

1. Frontmatter i
2. TABLE OF CONTENTS vii
3. Foreword xi
4. Abbreviations xiii
5. Doctrine
6. Discerning the Meaning of “Habitual Residence of the Child” in UK Courts – A Case for the Oracle of Delphi 1
7. The EU Succession Regulation before the German Courts 2016-2019 37
8. Cross-Border Litigation – New Data, Initial Brexit Implications in England and Wales and Long-Term Policy Choices 57
9. On the Doctrinal Beginnings of the Conflict of Laws 101
10. Interim Measures in International Commercial Litigation. Proceedings of the SICL’s 31^st Private International Law Day – Lausanne, 23 May 2019
11. Interim Measures at the Crossroads of International Litigation and Arbitration – Some Remarks on Concurrent Jurisdiction and Cross- Border Enforcement 137
12. Interim Measures in English Law and their Circulation 159
13. The Recognition and Enforcement of Foreign Interim Measures in Switzerland 175
14. The Law Applicable to Provisional and Protective Measures – With a Focus on the EU System of Ancillary Reliefs 197
15. Jurisdiction to Grant Interim Measures in Support of Arbitration – The Influence of European Law 225
16. Swiss Practice of Interim Relief in International Arbitration 237
17. Interim Measures in International Arbitration – An Arab Perspective 259
18. The 2019 Hague Judgments Convention
19. The Jurisdictional Filters of the HCCH 2019 Judgments Convention 279
20. Thou Shall (Not) Pass – Grounds for Refusal of Recognition and Enforcement under the 2019 Hague Judgments Convention 309
21. Refusal of Recognition and Enforcement of Foreign Judgments on Public Policy Grounds in the Hague Judgments Convention – A Comparison with The 1958 New York Convention 333
22. Establishment of Treaty Relations under The 2019 Hague Judgments Convention 365
23. National Reports
24. International Jurisdiction of the Rabbinical Courts in Claims for Divorce in Israel 381
25. The Connecting Factor of the Place of Celebration of Marriage in Swiss Private International Law 399
26. Recognition of Foreign Same-Sex Unions in China 425
27. The lex loci delicti Rule in Canadian Conflict of Laws 457
28. Law of Succession to Estates of Deceased Persons in Chilean Private International Law 489
29. Court Decision
30. Foreign Proprietary Security Rights Failing to Comply with National Publicity Standards to Be Accepted? On Case No. 3 OB 249/18S of the Austrian Supreme Court of Justice 509
31. Forum
32. The Legal Position of the Weaker Party in B2B Relationships with Online Platforms in the European Union – An Analysis of Dispute Resolution Mechanisms in Regulation (EU) 2019/1150 523
33. “Almost” Universal Jurisdiction 549
34. Public Policy Exceptions in U.S. and European Private International Law – An Ultimate Fortress for Social and Environmental Standards? 569
35. Choice of Law in The European Union – Common Law Procedure and Evidence 589
36. Decentralized Autonomous Organizations (DAOs) in the Swiss Legal Order 601
37. Bridging the Gap in the OHADA Treaty with Respect to the Interpretative Role of the CCJA in Arbitration Matters 639
38. Index 663