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Articles 31 - 32 of 32
Full-Text Articles in Law
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.
A New Uniform Law For The International Sale Of Goods: Is It Compatible With American Interests?, Martin L. Ziontz
A New Uniform Law For The International Sale Of Goods: Is It Compatible With American Interests?, Martin L. Ziontz
Northwestern Journal of International Law & Business
The prospects for adoption of a law gov- erning commercial' contracts for the international sale of goods should be of compelling interest to American merchants and their legal advi- sors. The text which was presented to the diplomatic conference in March was completed by the United Nations Commission on Interna- tional Trade Law (UNCITRAL) in 1978.1 Its eighty-two articles em- body the substantive revisions of a similar document that was rejected by the United States sixteen years ago'--the 1964 Hague Convention Relating to a Uniform Law for the International Sale of Goods