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English Contract Law: Choice of Law and Forum Trumped?

In Fern Computer Consultancy Ltd v Intergraph Cadworx & Analysis Solutions Inc [2014] EWHC 2908 (Ch) (29 August 2014), the English High Court analyzed the arguments for and against non-English forum selection and choice of...more

English Contract Law: Has the Camel’s Nose of “Good Faith” Crept Under the Tent Flap?

Under the English Arbitration Act 1996 the grounds on which an English arbitration award can be challenged in court are very limited. Section 67 of the Act provides that a challenge may be brought on the basis that the...more

An American Policyholder in London: English Choice of Law Clauses in United States Insurance Policies

While certainly not the norm, it is not uncommon for insurance policies issued to companies based in the United States, particularly large commercial and excess policies brokered on the London Market, to contain choice of law...more

3/21/2014  /  Choice-of-Law , Jurisdiction , UK
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