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Silence Is Not Submission: Chinese Court Refuses to Enforce U.S. Default Judgment Rendered in Breach of Arbitration Agreement
Written by Dr. Meng Yu, lecturer at China University of Political Science and Law, and co-founder of China Justice Observer.
ABSTRACT
In around 2019, a Chinese court in Hebei Province refused to enforce a US default monetary judgment from a California court on the grounds that a valid arbitration agreement was in place (Sunvalley Solar Inc. v Baoding Tianwei Solarfilms Co. Ltd. (2019) Ji 01 Xie Wai Ren No. 3). This decision underscored the court’s reliance on the arbitration agreement’s validity, even though a subsequent legislative proposal to include arbitration agreements as an indirect jurisdictional filter in China’s Civil Procedure Law (2023 Amendment) was ultimately not adopted.
The Validity of the Utah Zoom Wedding in Lebanon, or the Question of Locus Celebrationis in the Digital Age
Many thanks to Karim Hammami for the tip-off
I. Introduction
Once in the 20th century, the so-called “Nevada Divorces” captured the attention of private international law scholars around the world, particularly regarding their recognition abroad. Today, a similar phenomenon is emerging with the so-called “Utah Zoom Wedding.” So, what exactly is this phenomenon? Read more
Rethinking Private International Law Through the Lens of Colonialism
Last week (7 June 2025), I had this extraordinary opportunity to give a presentation at the 138th Annual Conference of the Japanese Association of Private International Law, which took place at Seinan Gakuin Daigaku, Fukuoka – Japan. The theme of my presentation was “Private International Law and Colonialism.” In this talk, I shared some preliminary thoughts on a topic that is both extraordinarily rich and complex. The following note offers some initial reflections based on that presentation (with a few adjustments) with the aim of contributing to ongoing discussion and encouraging deeper reflection.
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Report on the 4th Asian Private International Law Academy (APILA) Conference
The 4th Asian Private International Law Academy (APILA) Conference was held on 13–14 December 2025 in Doshisha University (Kyoto, Japan). The two-day Conference explored a wide variety of questions and issues on private international law in Asia. It featured 21 papers delivered by leading and emerging scholars. Each paper was followed by a Q&A and discussion session among over 40 attendees. Attendees thoroughly enjoyed the rich intellectual exchanges within the close-knit (and expanding) community of APILA, and also the reception (with an impressive selection of food and drinks) on the first night of the Conference.
Conflict of laws in the South African courts: a recent missed opportunity
Posted on behalf of Jason Mitchell, barrister at Maitland Chambers in London and at Group 621 in Johannesburg.
It’s rare for conflict of laws to come up in South African courts (with the notable exception of the Turkcell litigation from earlier this year; see the summary on this site at https://conflictoflaws.net/2025/south-africa-grapples-with-the-act-of-state-doctrine-and-choice-of-law-in-delict/).
Symeonides on Private International Law Bibliography 2025: U.S. and Foreign Sources in English
There is no better Christmas present than a comprehensive and up-to-date compilation of the previous year’s scholarship in private international law, and when that bibliography is prepared by Professor Symeon C. Symeonides (Alex L. Parks Distinguished Professor of Law, Dean Emeritus), it is truly something special.
As usual, and without fail for the past twenty years, Professor Symeonides has produced an exceptionally thorough and reliable survey of the field.
The 2025 compilation (Private International Law Bibliography 2025: U.S. and Foreign Sources in English) lists no fewer than 115 books and 397 journal articles devoted to private international law (or conflict of laws) and related areas.
The Absract reads as follows:
“This is the twentieth annual bibliography of private international law compiled by the undersigned as a service to fellow teachers and students of this subject. It includes 115 books and 397 journal articles that appeared in print in 2025.
The term “private international law” is used here in the broadest and arguably expanded sense. It encompasses not only the three divisions of the law of conflict of laws (adjudicatory jurisdiction, choice of law, and recognition of sister-state and foreign judgments), but also prescriptive jurisdiction, extraterritoriality, federal-state conflicts, as well as certain aspects of arbitration, the law of foreign relations, and international human rights.
AI Note: This compilation is the product of human labor-mine. I have visually verified all entries, although I have used electronic search engines to locate them. I have not used generative artificial intelligence (AI).
Access to the bibliography is available on Prof. Symeonides’ SSRN page here.
Readers may also wish to consult his insightful essay, Reflections from Fifty Years in the Conflicts Vineyard, in which he offers a concise yet profound and wide-ranging reflection on half a century of scholarship in the field, available here
Many thanks to Professor Symeonides for this invaluable contribution, which continues to be an essential resource for scholars and practitioners alike.