This dissertation aims at offering a comparative study of the Rome Convention 1980 on the law applicable to contracts and the US law regarding the limits to the doctrine of freedom of choice of law by the parties. Finally, Rome I, a Regulation proposed by the European Commission to replace the Rome Convention 1980, will be examined in order to locate the positive and/or negative aspects of such an attempt, as well as the contribution that this development could bring about to the promotion of the integration of the Internal Market. Particularly, the specific limits set by the mandatory rules of article 7 of the Rome Convention 1980, as well as those set by the public policy of the forum in article 16 will be analyzed and compared to the relevant provisions of the US law entailed in paragraphs 187(2) (b) of the Restatement Second and 1-105 of the Uniform Commercial Code.
Comparative analysis of the limits to party autonomy under EU and US law. Articles 7 and 16 of the Rome Convention and articles 187(2)(b) of the Restatement Second and 1-105 of the Uniform Commercial Code
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Книга по Требованию
Сравнительные степени прилагательных и наречий (Comparison) Модальные глаголы (Modal Verbs) Цепочки...
Порядок перевода слов в атрибутивных группах может быть различным и определяется по смыслу, например: Low empera ure physics – физика низких температур.5.Выделение атрибутивной группы 1 2 облегчается наличием различных суффиксов существительного 2 (-er (-or), -me , -io (- io , -sio )), например: We compare he levels of machi e vibra io s wi h biological sys ems.6.Наличие явного сказуемого (is, are, was, were, have, had, has, mus , ca , may) – облегчает поиск атрибутивной группы 1 2, выступающей в функции подлежащего, например: Sou d waves are a alyzed by he compu er every o e-hu dred h of a seco d.7.Атрибутивная группа 1 2 может входить в состав подлежащего и вводиться при помощи различных предлогов (of, a , i ), например: A ew ype of laser beam has bee developed by Byelorussia scie is s, где, 1 2 /laser beam/, стоящее перед явным сказуемым «has bee developed», вводится в группу подлежащего при помощи предлога rai .
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