Comparative Conflict of Laws in Contractual and Non-Contractual Obligations
This course will cover new developments in conflict of laws rules within the European Union as laid down in two recent EC regulations on the Law Applicable to Contractual Obligations (Rome I Regulation) and on the Law Applicable to Non-Contractual Obligations (Rome II Regulation). The Rome I Regulation will enter into force by the end of 2009, while Rome II Regulation entered into force in January 2009. They will be the conflict of laws rules in all Member States of the European Union (except for Denmark). Hence, knowledge of these developments is of special interest to lawyers interested in international transactions. Coverage will include a comparison of recent developments in Europe and developments in the United States.