This is the third and last in a series of posts comparing the new Hague Principles on Choice of Law in International Commercial Contracts and the Restatement (Second) of Conflict of Laws. Before digging in, I want to give you the analysis of the two texts by my co-author, Jonathan Levin. His lengthy and detailed table was the genesis of the whole project, so I recommend it to you.
(more…)

Today I bring you the second post in our series comparing the new Hague Principles on Choice of Law and the Restatement (Second) of Conflict of Laws. I say “I,” but I mean “we.” Jonathan Levin, who interned this summer at the Permanent Bureau of the Hague Conference, is a co-author of these posts.
(more…)

As promised, here is the first post in what I hope will be a short series of posts comparing the new Hague Principles on Choice of Law in International Commercial Contracts and the Restatement (Second) of Conflict of Laws. I had a pleasant surprise after noting the publication of the Principles last month: Marta Pertegás, the First Secretary of the Permanent Bureau of the Hague Conference, took an interest in the idea of the post. From this, Jonathan Levin, an NYU law student who is interning this summer at the Permanent Bureau, independently offered to conduct a comparative study for the purposes of these posts. I’ll publish his report with the last post in the series.
(more…)