Party Autonomy in the Private International Law of Contracts
Giesela Ruehl (Max Planck Institute for Comparative and Private International Law) has posted Party Autonomy in the Private International Law of Contracts: Transatlantic Convergence and Economic Efficiency on SSRN. Here's the abstract: It is commonly acknowledged that during the 20th century American and European choice-of-law theory have drifted apart: in the United States the American […]