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Tatlici v. Tatlici on Appeal: Defendant Wins as Public Policy Confronts the Financialization of Cross-Border Defamation Award
Written by Fikri Soral, Independant Lawyer, Turkey; and LL.M. student, Galatasaray University, Turkey
The Tatlici litigation continues to unfold as one of the most noteworthy examples of how national courts in Europe are responding to transnational defamation judgments obtained in the United States. The previous commentary examined Malta’s First Hall Civil Court judgment refusing to enforce the U.S. default award of US$740 million.[1] The Malta Court of Appeal’s judgment of 14 October 2025 builds upon that foundation by upholding non-enforcement while clarifying the legal reasoning behind it.[2] The Malta Court of Appeal’s judgment came as the second major development, following an earlier first-round enforcement attempt in Turkey that had already failed on venue.[3] Read more
‘Paramount clause’ in a bill of lading as choice of law under Rome I – the Supreme Court of the Netherlands in Airgas USA v Universal Africa Lines
In Airgas USA v Universal Africa Lines (7/11/2025, ECLI:NL:HR:2025:1665), the Supreme Court of the Netherlands considered the interpretation of a so-called ‘Paramount clause’ in a bill of lading. Such clauses commonly signpost which rules govern the international carriage of goods by sea. The Court addressed such clause as a choice of law and held that article 3(1) of the Rome I Regulation does not preclude the parties from agreeing on such clause. Read more
“Without Regard to Principles of Conflict of Laws”
It is common to see some variation of the phrase “without regard to conflict of laws principles” appear at the end of a choice-of-law clause. Here are some examples:
“This Agreement shall be governed by and construed in accordance with the laws of the Republic of China, without regard to its principles concerning conflicts of laws.”
“This Agreement and all acts and transactions pursuant hereto and the rights and obligations of the parties hereto shall be governed, construed and interpreted in accordance with the laws of the State of Delaware, without giving effect to principles of conflicts of law.”
“This Note is being delivered in and shall be construed in accordance with the laws of the State of New York, without regard to the conflict of laws provisions thereof.”
Although this phrase is common, its purpose and origin are poorly understood. In 2020, I published an article, A Short History of the Choice of Law Clause, that attempted to demystify these issues.
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PAX Moot 2026 Vladimir Koutikov Round has come to an end – announcement of winners
This post has previously been published by PAX Moot (with minor changes). Photo: University of Ljubljana Team.
The PAX Moot 2026 — Vladimir Koutikov Round has come to an end, and what an incredible edition it has been. We hope it was an unforgettable experience for all participants — a unique opportunity to engage in high-level argumentation on Private International Law, grow advocacy skills, and forge lasting friendships along the way.
Without further ado, we are proud to announce the results of this year’s competition:
- Winner — University of Ljubljana
- Runner-up — Sofia University St. Kliment Ohridski
Call for Contributions (International Conference and Edited Volume): Imagining Decolonial Legal Methods in Europe (Pushing Boundaries)
The following Call for Contributions has been kindly shared with us by Sandrine Brachotte (UAntwerpen):
Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 3/2026: Abstracts
The latest issue of the „Praxis des Internationalen Privat- und Verfahrensrechts“ (IPRax) features the following articles: