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The Termination Of Agency And Distributorship Agreements: A Comparative Survey, A.H. Puelinckx, H.A. Tielemans
The Termination Of Agency And Distributorship Agreements: A Comparative Survey, A.H. Puelinckx, H.A. Tielemans
Northwestern Journal of International Law & Business
The termination of agency agreements in most EEC Member States is regulated by statute, while the termination of distributorship agreements, with the exception of Belgium, is governed by case law. Messrs. Puelinckx and Tielemans first survey the state of the law governing the termination of agency and distributorship agreements in the EEC Member States and then discuss the efforts of the EEC to harmonize the national laws of the Member States in the area of commercial representation. The authors conclude by supporting the EEC harmonization effort relating to the laws regulating agency agreements and by calling for further efforts to …
Characteristic Performance -- A New Concept In The Conflict Of Laws In Matters Of Contract For The Eec, Kurt Lipstein
Characteristic Performance -- A New Concept In The Conflict Of Laws In Matters Of Contract For The Eec, Kurt Lipstein
Northwestern Journal of International Law & Business
The concept of "characteristic performance, " used in conflicts law to determine which country's law applies in the absence of an express or implied choice of law, has been incorporated into Article 4 of the Draft Convention on the Law Applicable to Contractual and Non-Contractual Obligations. In this article, Professor Lipstein examines the purpose, history, and criticisms of the concept of "characteristic performance" and concludes by supporting the use by the Member States of characteristic performance as a means of determining the legal system governing the contract as a whole.