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Jurisdiction United Kingdom Choice-of-Law

Latham & Watkins LLP

FMLC Proposes New Rule on Governing Law for Digital Assets

Latham & Watkins LLP on

Proposed rule would be implemented by statute and would give primacy to parties’ choice of governing law and jurisdiction. There is at least a tentative consensus in English law that cryptocurrencies and other digital...more

BCLP

The Arbitration Act 2024: an Aggregation of Marginal Gains

BCLP on

The Law Commission of England and Wales has concluded its review of the Arbitration Act 1996. In our International Arbitration Survey 2022, we canvased views on the potential areas for reform of the Act....more

Holland & Knight LLP

Brexit: Implications for Dispute Resolution

Holland & Knight LLP on

Brexit has well and truly arrived, and while the trade agreement that was reached on Christmas Eve 2020 is undoubtedly a very significant development in terms of the future relationship between the United Kingdom and European...more

White & Case LLP

Dallah Revisited: The French and English Courts in Conflict Again Regarding Arbitral Jurisdiction Over Non-Signatories

White & Case LLP on

The ongoing Kout Food saga provides a salutary reminder that difficult issues can sometimes arise when parties choose different systems for the substantive law of their contractual relationship and the curial law of the seat...more

Akin Gump Strauss Hauer & Feld LLP

The Law of an Arbitration Agreement: Is it the law of the seat or the law of the underlying contract?

If there is no express law of the arbitration agreement, the law with which that agreement has its closest and most real connection is either the law of the underlying contract or the law of the seat of the arbitration. The...more

WilmerHale

International Comparative Legal Guide to International Arbitration 2019 - Chapter Thirty Two: England & Wales

WilmerHale on

What, if any, are the legal requirements of an arbitration agreement under the laws of your jurisdiction? There are no formal requirements for an arbitration agreement to be valid. However, the Arbitration Act 1996 (the...more

Dorsey & Whitney LLP

UK Litigation in a Post Brexit World

Dorsey & Whitney LLP on

As in so many other areas, the effect of the decision to leave the European Union in the referendum on 23 June 2016 on litigation in England and Wales in still highly uncertain. There are a number of issues that the UK...more

Locke Lord LLP

Brexit: What You Need To Know - Litigation

Locke Lord LLP on

As the intertwined laws of the UK and the EU are unravelled in the exit negotiations, changes to litigation seem inevitable. Contracts: At the moment the changes are unknown and in particular we do not know if any...more

King & Spalding

Brexit; Assessing the impact on Middle Eastern issuers accessing the UK and European Capital Markets

King & Spalding on

Many companies and other entities in the Middle East tap the UK and/or European debt and equity capital markets as part of achieving their corporate funding and broader strategic objectives. Whilst the precise legal and...more

K&L Gates LLP

"Brexit Bites": Dispute Resolution Implications

K&L Gates LLP on

This is the tenth in our series of "Brexit Bites" which focuses on Dispute Resolution If the UK exits the EU, there could be implications for any dispute resolution process involving English law and English courts. Much...more

K&L Gates LLP

"Brexit Bites": Dispute Resolution

K&L Gates LLP on

This is the ninth in our series of "Brexit Bites" which focuses on Dispute Resolution. If the UK exits the EU, there could be implications for any dispute resolution process involving English law and English courts....more

Dechert LLP

English High Court considers co-existence provisions under German and English law

Dechert LLP on

In two recent IP decisions in the English High Court, the interpretation of a settlement agreement and a co-existence agreement have been carefully considered. In DKH Retail and Others v SRG Apparel Plc and Others, English...more

McDermott Will & Emery

Ruling on UK Executive’s Lawsuit Involving U.S.-Based Stock Option Plan

McDermott Will & Emery on

English executives employed by multinational companies often have a contract of employment with the company’s UK subsidiary, but may also participate in a separate bonus or share option plan that contains foreign (e.g., U.S.)...more

Pillsbury Winthrop Shaw Pittman LLP

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

Pillsbury Winthrop Shaw Pittman LLP

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

Morgan Lewis

UK High Court Revisits Issue of Where a Contract Is Formed

Morgan Lewis on

Court confirms that, in certain circumstances, a contract can be made in two jurisdictions. On 7 October 2013, in Conductive Inkjet Technology Ltd v Uni-Pixel Displays Inc, [2013] EWHC 2968 (Ch), the High Court of...more

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