A Textbook Example of Art 17 Rome II: Higher Regional Court of Cologne, 27 March 2020
Art. 17 of the Rome II Regulation, which transposes an element of US conflicts theory (the concept of local data) into a European choice-of-law instrument, is certainly one of the more controversial provisions of the Regulation. It stipulates that [i]n assessing the conduct of the person claimed to be liable, account shall be taken, as […]