Chapter 5 presents the enforcement of asymmetric arbitration and jurisdiction clauses in such leading European jurisdictions like the United Kingdom, France and Germany. Besides these countries, the chapter summarises the development of judicial practice in the USA, Russia, in Hungary and in some other civil law and common law jurisdictions. The Chapter ends with identifying the limits of the international choice of forum which are relevant for asymmetric choice of forum agreements.

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Asymmetric Choice of Forum Clauses in Practice

  • Richard Schmidt

摘要

Chapter 5 presents the enforcement of asymmetric arbitration and jurisdiction clauses in such leading European jurisdictions like the United Kingdom, France and Germany. Besides these countries, the chapter summarises the development of judicial practice in the USA, Russia, in Hungary and in some other civil law and common law jurisdictions. The Chapter ends with identifying the limits of the international choice of forum which are relevant for asymmetric choice of forum agreements.