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'Domesticating' The New York Convention: The Impact Of The Federal Arbitration Act, George A. Bermann
'Domesticating' The New York Convention: The Impact Of The Federal Arbitration Act, George A. Bermann
Faculty Scholarship
Much as one may try to universalize and even ‘de-nationalize’ international commercial arbitration – whether through Conventions, uniform or model laws or soft law – the phenomenon remains profoundly affected by national law and policy. That is indeed very much one of the leitmotifs of this book.
The incongruities – big and small – between domestic and international arbitration regimes typically present themselves on a purely ad hoc basis; that is to say, in specific and often isolated contexts, as when a particular case in a national court produces a result that looks anomalous from the point of view of …