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- Comparative Law; Judges; Transnational Law (2)
- Applicable law (1)
- Central American Integration (1)
- Choice of forum (1)
- Choice of law (1)
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- Conflict of laws (1)
- Consumer contracts (1)
- Consumer protection (1)
- Dispute resolution (1)
- European private law (1)
- International commercial law (1)
- International consumer law (1)
- Party autonomy (1)
- Private international law (1)
- Regional Integration; Central American Identity; Constitutional Borrowing (1)
- Rome I (1)
- Transnational Constitutional Law; European Law (1)
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Articles 1 - 3 of 3
Full-Text Articles in Rule of Law
The Central American Constitutional Identity. A Study Of The Constitutional Imitation Phenomenon In The Integration Process Of The Region, Prof. Michele Carducci
The Central American Constitutional Identity. A Study Of The Constitutional Imitation Phenomenon In The Integration Process Of The Region, Prof. Michele Carducci
Michele Carducci Prof.
No abstract provided.
Is “Transnational” Constitutional Law Possible?, Prof. Michele Carducci
Is “Transnational” Constitutional Law Possible?, Prof. Michele Carducci
Michele Carducci Prof.
No abstract provided.
The Rome I Regulation Rules On Party Autonomy For Choice Of Law: A U.S. Perspective, Ronald A. Brand
The Rome I Regulation Rules On Party Autonomy For Choice Of Law: A U.S. Perspective, Ronald A. Brand
Articles
This chapter was presented at a conference in Dublin on the (then) new Rome I Regulation of the European Union in the fall of 2009. It contrasts the Rome I rules on party autonomy with those in the United States. In particular, it considers the rules in the Rome I Regulation that ostensibly protect consumers by discouraging party agreement on a pre-dispute basis to the law governing a consumer contract. These rules are compared with the absence of private international law restrictions on choice of forum and choice of law in the United States, even in consumer contracts. The result …