Last week’s guest post by Pietro Franzina discussed the proposal of the EU Commission, recently adopted, that the EU should become a party of the Hague Convention on Choice of Court Agreements. Today, Ted Folkman provides the U.S. perspective on the Convention on his blog, Letters Blogatory, following up on an earlier post on the different proposals on how to implement the Convention in the U.S. system of state and federal courts. Ted, in short, believes that the Convention should be adopted and that in the real word, the differences between the rivalling approaches will not be felt.
Addendum: Here is a link to the comments of the German Bar Association (Deutscher Anwaltverein) dated October 2013. The German Bar Association welcomes the ratification, in particular with a view to transatlantic business. Its comments contain recommendations as to the declarations the European Union should or should not make pursuant Art. 19 – 21.
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