You might also like

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

• Book details
• Synopsis
• Trending among others

You get 137 loyalty points

Book synopsis

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.

Book details

Book category Books in English Law International law

• Full title: Comparative analysis of the limits to party autonomy under EU and US law
• Author: Zabia Vernadaki
• Language: English
• Binding: Paperback
• Number of pages: 60
• EAN: 9783639299885
• ISBN: 3639299884
• ID: 06837000
• Publisher: VDM Verlag
• Weight: 100 g
• Dimensions: 229 × 152 × 4 mm
• Date of publishing: 01. October 2010

Trending among others

---

---

---