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International tech litigation reaches the next level: collective actions against TikTok and Google
Written by Xandra Kramer (Erasmus University Rotterdam/Utrecht University) & Eduardo Silva de Freitas (Erasmus University Rotterdam), members of the Vici project Affordable Access to Justice, financed by the Dutch Research Council (NWO), www.euciviljustice.eu.
Introduction
We have reported on the Dutch WAMCA procedure for collective actions in a number of previous blogposts. This collective action procedure was introduced on 1 January 2020, enabling claims for damages, and has since resulted in a stream of (interim) judgments addressing different aspects in the preliminary stages of the procedure. This includes questions on the admissibility and funding requirements, some of which are also of importance as examples for the rolling out of the Representative Action Directive for consumers in other Member States. It also poses very interesting questions of private international law, as in particular the collective actions for damages against tech giants are usually international cases. We refer in particular to earlier blogposts on international jurisdiction in the privacy case against TikTok and the referral to the CJEU regarding international jurisdiction under the Brussels I-bis Regulation in the competition case against Apple.
Turning Point: China First Recognizes Japanese Bankruptcy Decision
This post is written by Guodong Du and Meng Yu and published at China Justice Observer. It is reproduced here by kind permission of the authors.
Key takeaways:
- In September 2023, the Shanghai Third Intermediate People’s Court ruled to recognize the Tokyo District Court’s decision to commence civil rehabilitation proceedings and the order appointing the supervisor ((2021) Hu 03 Xie Wai Ren No.1).
- This marks not only the first time that China has recognized a Japanese court’s decision in a bankruptcy procedure, but also the first time that China has recognized a Japanese judgment.
- The case establishes a legal precedent for cross-border bankruptcy decisions, demonstrating that prior non-recognition patterns between China and Japan in civil and commercial judgments may not apply in such cross-border scenarios.
- While not resolving the broader recognition challenges between the two nations, this acknowledgment sends a positive signal from the Chinese court, hinting at potential future breakthroughs and fostering hope for improved legal cooperation.
Disentangling Legal Knots: Intersection of Foreign Law and English Law in Overseas Marriages
Written by Muhammad Zubair Abbasi, Lecturer at School of Law, Oxford Brookes University (mabbasi@brookes.ac.uk)
Introduction:
In a recent judgment Tousi v Gaydukova [2024] EWCA Civ 203, the Court of Appeal dealt with the issue of the relevance of foreign law to the remedy available under English law in respect of an overseas ceremony of marriage. Earlier the High Court had held that the foreign law determines not only the validity or invalidity of the ceremony of marriage but also the ramifications of the validity or invalidity of the ceremony. The Court of Appeal disagreed and reiterated the rule that lex loci celebrationis is limited to the determination of the validity or invalidity of the ceremony of marriage. Therefore, English law will apply to provide a remedy or relief upon the breakdown of the relationship of the parties to a marriage ceremony that took place abroad.
News
Launch of the Bahrain International Commercial Court
The Bahrain International Commercial Court (BICC) was launched on 5 November 2025. It joins the long established Dubai International Financial Centre Courts, Abu Dhabi Global Market Courts and Qatar International Court and Dispute Resolution Centre in the Middle East as a specialist court devoted to resolving international commercial disputes and operating under special procedural rules.
The BICC was developed in partnership with the Singapore International Commercial Court (SICC). It shares many key features with the SICC such as a multinational bench, foreign counsel representation and use of the English language in proceedings. Of particular note is the appeal mechanism for BICC judgments; as discussed previously here, appeals from the BICC will be heard by the International Committee of the SICC.
ASADIP Conference Rio 2025 (report) and San Salvador 2026 date (20-23 October)
The ASADIP conference is an annual highlight of the discipline. The reports from the 2025 conference in Rio de Janeiro are now available, in English, Spanish, and Portuguese, here
And the location and date for the 2026 have been set for San Salvador, El Salvador, 20-23 October. See you there.
Short report: Conference on Sustainable Global Value Chains and Private International Law
On 17 October 2025, the EBS Law School in Oestrich-Winkel, Germany, hosted a conference Sustainable Global Value Chains and Private International Law. The conference was organised by Professors Veronica Ruiz Abou-Nigm (Edinburgh Law School) and Michael Nietsch (EBS Law School) as part of the Law Schools Global League Sustainable Global Value Chains Project (see also here).
The conference brought together a number of scholars specialised in private international law, company law, and contract law to discuss the role of private law and private international law in social, economic, and environmental sustainability within global value chains.
Keynote
Ralf Michaels (Max Planck Institute for Comparative and International Private Law, Hamburg, Germany) delivered the keynote lecture entitled “European Law for Global Value Chains – Human Rights Advancement or European Imperialism?” Professor Michaels addressed this question from a historical perspective. He related the historical roots of existing sourcing practices to contemporary supply chains, drawing on a wealth of theoretical insights. He further reflected on the conceptualisations that remain necessary for the legal discipline to contribute to addressing economic inequalities in contemporary global sourcing practices facilitated by interconnected chains of contracts.
After the keynote, several scholars provided insights into their current research, which resonated with various aspects of the keynote lecture. Read more