By Eckart Gottschalk, Ralf Michaels, Giesela Ruhl, Jan von Hein
This ebook comprises ten contributions that research present issues within the evolving transatlantic discussion at the clash of legislation. the 1st 5 contributions care for the layout of judgments conventions usually, the lately followed Hague conference on number of court docket Agreements, difficulties related to adverse declaratory activities in foreign disputes, and up to date transatlantic advancements on the subject of provider of approach and collective lawsuits. the remainder 5 contributions specialise in comparative and fiscal dimensions of social gathering autonomy, number of legislation in relation to highbrow estate rights, the acceptable legislation in antitrust legislations litigation, foreign arbitration, and activities for punitive damages.
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No. 7 (April 1997), available at http://www. pdf, at 43–4, nos. 151–6. Brussels Convention on jurisdiction and the enforcement of judgments in civil and commercial matters of September 27, 1968, 1998 O. J. (C 27) 1 (consolidated version). , at 19, 28–9. text&cid=98, published with an introductory note by Ronald A. Brand, 44 I. L. 1291 (2005) [hereinafter 2005 Hague Choice of Court Convention]. , Chapter 5, in this volume. ¨ die Haager VerArthur T. von Mehren & Ralf Michaels, Pragmatismus und Realismus fur ¨ handlungen zu einem weltweiten Gerichtsstands- und Vollstreckungsubereinkommen, 25 DAJVNewsletter 124, 127 (2000); Arthur T.
14 Jurisdiction is different from rights (although the legal relations it creates can be modeled in Hohfeldian terms). Nevertheless, von Mehren’s insights on the relation between jurisdiction and enforcement yield insights that are strikingly similar. This section will formalize these thoughts, and the concept of the mixed convention, in three separate steps. 1. Required, Excluded, and Permitted Bases A first issue concerns the design of judgments conventions, more specifically the structure of rules on individual bases of jurisdiction.
Comp. L. 191 (2001); also published in A Global Law of Jurisdictions and Judgments: ´ III & K. M. , 2002). Lessons from The Hague (J. J. Barcelo, Peter D. Trooboff, Remarks at the Memorial Service, Apr. 19, 2006 (quoting the current State Department Legal Advisor John Bellinger III). Peter Nygh, Arthur’s Baby: The Hague Negotiations for a World-wide Judgments Convention, in Law and Justice in a Multistate World, supra note 12, at 151. The talk was later reproduced as Arthur T. von Mehren, Recognition of United States Judgments Abroad and Foreign Judgments in the United States, 57 RabelsZ 449 (1993).