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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.

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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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News

Seminar on International Insolvency and 2026 Seminar Series on the Reform of the Brussels I bis Regulation (Universidad Autónoma de Madrid)

The Área de Derecho Internacional Privado of the Universidad Autónoma de Madrid (UAM) announces two initiatives of particular interest for scholars and practitioners of private international law.

1. Seminar: Nuevas perspectivas de la insolvencia internacional: reestructuraciones preconcursales y concursales

On Friday, 6 March 2026 (12:45), a seminar will be held at the Faculty of Law of UAM (Seminario II) in the framework of the research project “Nuevas perspectivas de la insolvencia internacional: reestructuraciones preconcursales y concursales” (PID 2022-140017OB100), coordinated by Professors Iván Heredia Cervantes and Elisa Torralba Mendiola. Read more

FAMIMOVE is back! – FAMIMOVE 3.0 starts on 1 March 2026

FAMIMOVE 3.0 is an international project co-funded by the European Commission under the JUST-2025-JCOO program. The project’s full name is Families on the Move: The Coordination between international family law and migration law.

This project seeks to build on the results of FAMIMOVE 2.0 by focusing on children on the move in vulnerable situations and by consolidating the networks already established of experts in family law, child protection and migration law. It involves 7 universities in 6 EU Member States.

The duration of the project is two years from 1 March 2026 to 29 February 2028.

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SLS Annual Conference 2026: Private International Law Section: Call for Papers

The following call was kindly shared with us by Michiel Poesen (University of Aberdeen).

This is a call for papers and panels for the Private International Law subject section at the SLS Annual Conference 2026. This year, the annual conference will take place at the University of East Anglia in Norwich. The conference dates are: 2-4 September 2026. SLS Conference

The Private International Law section will meet in the first half of the conference on 2-3 September, and we can run up to four sessions, each lasting 90 minutes.?Doctoral students are very welcome and are encouraged to submit papers for consideration in the Subject Sections Programme. The conference theme is Doing Law Differently, but the Private International Law Subject Section welcomes paper and panel proposals on any topics connected to our discipline.

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