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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.
News
EAPIL Conference in Geneva (18-20 June 2026): Early bird registration ends on 15 March!
As report earlier on this blog, the third bi-annual conference of the European Association of Private International Law (EAPIL) will take place in Geneva, Switzerland, from 18 to 20 June 2026. Under the title “Shaping the Future of Private International Law in Europe – Putting Together the Pieces & Filling Gaps”, the conference will address structural developments, unresolved issues, and emerging challenges in European private international law. The program is available on the conference’s website.
Early bird registration will close on 15 March 2026. You are welcome to register using this link.
EAPIL is looking forward to seeing you in Geneva!
Praxis des Internationalen Privat- und Verfahrensrechts (IPRax) 2/2026: Abstracts
The latest issue of the „Praxis des Internationalen Privat- und Verfahrensrechts“ (IPRax) features the following articles:
Registration open: Australasian Association of Private International Law Conference, Sydney, 16-17 April 2026
Registrations for the 2026 AAPrIL Conference, to be held on 16 and 17 Apriil 2026, are now open!
VENUE: Ashurst Lawyers
Level 8, 39 Martin Place
Sydney, New South Wales 2000
AUSTRALIA
PANELS AND SESSIONS:
- Jurisdiction
- Private International Law and Digitalisation
- Regional and International Cooperation
- Arbitration
- Applicable Law
Attendance at conference sessions can be used for CPD; you will need to check local requirements.
REGISTRATION FEES:
If you are coming for both days, please select Friday.
Non-member 2 days: $160
Non-member 1 day: $90
AAPrIL member 2 days: $120
AAPrIL member 1 day: $70
Student: Free to attend the conference only
Conference dinner: $110 for dinner and a selection of drinks
REGISTRATION INCLUDES:
Access to all conference sessions
Morning tea and coffee, morning teas and lunches
Access to purchase a conference dinner ticket at an additional cost of $110