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Book(electronic)2014
Codifying Choice of Law Around the World: an International Comparative Analysis
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Abstract
3. Closer Connection as an Exception from Both the Lex Loci and the Parties' Common Law4. Common Party Affiliation as the Sole Exception; C. The Common Domicile Exception or Rule; 1. The Common Affiliation; 2. The Various Versions of the Common-Domicile Rule; a. Express Bilateral Rule; b. Implied Common-Domicile Rule; c. Unilateral Common-Domicile Rule; d. Summary and Comparison; D. Parties Domiciled in States with the Same Law; E. The Preexisting Relationship Exception; F. The Double Actionability Rule; G. Other Unilateral Exceptions in Favor of the Lex Fori; V. Rules of "Conduct and Safety."
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Book(electronic)#22014
Codifying Choice of Law Around the World: An International Comparative Analysis
Codifying Choice of Law Around the World chronicles, documents, and celebrates the extraordinary, massive codification of Private International Law (PrIL), or Conflict of Laws that has taken place in the last 50 years, from 1962-2012. During this period, the world has witnessed the adoption of nearly 200 PrIL codifications, EU Regulations, and international conventions---more than in all preceding years since the inception of PrIL. This book provides a horizontal comparison and discussion of these codifications and conventions, first by comparing the way they resolve tort and contract conflict
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