Editing Conflict of laws

{{Short description|Law for cases in multiple jurisdictions}}
{{Use mdy dates|date=August 2021}}
{{Conflict of laws}}

'''Conflict of laws''' (also called '''private international law''') is the set of rules or laws a [[jurisdiction]] applies to a [[Legal case|case]], [[Transactional law|transaction]], or other occurrence that has connections to more than one jurisdiction.<ref name="Blacks">"Conflict of Laws", ''Black's Law Dictionary'' (11th ed. 2019).</ref> This body of law deals with three broad topics: ''jurisdiction'', rules regarding when it is appropriate for a court to hear such a case; ''foreign judgments'', dealing with the rules by which a court in one jurisdiction mandates compliance with a ruling of a court in another jurisdiction; and ''[[choice of law]]'', which addresses the question of which substantive laws will be applied in such a case.<ref name = "Restatement">Restatement of the Law—Conflict of Laws, ''§2: Subject Matter of Conflict of Laws'' (American Law Institute 1971).</ref> These issues can arise in any [[private law]] context,<ref name="Restatement"/> but they are especially prevalent in [[contract law]]<ref>{{Cite book |author=Briggs |title=The Conflict of Laws |year=2008 |pages=2–3}}</ref><ref>{{Cite book |author1=Clarkson |author2=Hill |title=The Conflict of Laws |year=2006 |pages=2–3}}</ref><ref>{{Cite book |author=Collins |title=''[[Dicey Morris & Collins|Dicey, Morris and Collins on The Conflict of Laws]]'' |year=2006 |at=p. 36 (paras. 1-087 et seq.)}}</ref><ref>{{Cite book |author1=Hay |author2=Borchers |author3=Symeonides |title=Conflict of Laws |year=2010 |pages=1–3}}</ref><ref>{{Cite book |author1=McClean |author2=Beevers |title=The Conflict of Laws |year=2009 |at=pp. 4–5 (para. 1-006)}}</ref><ref>{{Cite book |author1=North |author2=Fawcett |title=Cheshire and North's Private International Law |year=1999 |pages=13–14}}</ref><ref>{{Cite book |author=Rogerson |title=Collier's Conflicts of Laws |year=2013 |pages=3–4}}</ref><ref>{{Cite book |author=Symeonides |title=American Private International Law |year=2008 |at=pp. 15–16 (para. 2)}}</ref> and [[tort law]].<ref name="EU_Reg864">[https://eur-lex.europa.eu/legal-content/EN/TXT/?qid=1459818518522&uri=CELEX:32007R0864 Regulation (EC) No 864/2007 of the European Parliament and of the Council of 11 July 2007 on the law applicable to non-contractual obligations (Rome II)].</ref>

== Scope and terminology ==
The term ''conflict of laws'' is primarily used in the United States and Canada, though it has also come into use in the United Kingdom. Elsewhere, the term ''private international law'' is commonly used,<ref name="Blacks"/> for example in [[law of Switzerland|Switzerland]], the Federal Act on Private International Law (PILA) regulates which law should be applied when a dispute has connections with more than one jurisdiction.<ref>SwissRights, [https://www.swissrights.ch/gesetze/IPRG-EN Federal Act on Private International Law (PILA) - all articles with explanations], accessed on 9 April 2025</ref> Some scholars from countries that use ''conflict of laws'' consider the term ''private international law'' confusing because this body of law does not consist of laws that apply internationally, but rather is solely composed of domestic laws; the calculus only includes international law when the nation has treaty obligations (and even then, only to the extent that domestic law renders the treaty obligations enforceable).<ref>"International Law: Private International Law", ''Black's Law Dictionary'' (11th ed. 2019).</ref> The term ''private international law'' comes from the [[private law]]/[[public law]] dichotomy in [[civil law system]]s.{{sfn|Cherednychenko|2007|page=22}}<ref>{{cite journal |last1=Dodge |first1=William S. |date=2008 |title=The Public-Private Distinction in the Conflict of Laws |journal=Duke Journal of Comparative and International Law |volume=18 |pages=371-394 }}</ref> In this form of legal system, the term ''private international law'' does not imply an agreed upon international legal [[Text corpus|corpus]], but rather refers to those portions of domestic private law that apply to international issues.

Importantly, while conflict of laws generally deals with disputes of an international nature, the applicable law itself is domestic law. This is because, unlike [[public international law]] (better known simply as ''international law''), conflict of laws does not regulate the relation between countries but rather how individual countries regulate internally the affairs of individuals with connections to more than one jurisdiction. To be sure, as in other contexts, domestic law can be affected by international treaties to which a country is party.

Moreover, in federal states where substantial lawmaking occurs at the subnational level, notably in the United States, issues within conflict of laws often arise in wholly domestic contexts, relating to the laws of different states (or provinces, etc.) rather than of foreign countries.

== History ==
Western legal systems first recognized a core underpinning of conflict of laws—namely, that "foreign law, in appropriate instances, should be applied to foreign cases"—in the twelfth century.<ref name="Yntema">{{cite web| url = https://repository.law.umich.edu/cgi/viewcontent.cgi?article=5681&context=mlr| title = Hessel E. Yntema, ''The Comity Doctrine'', 65 Michigan Law Review 9 (1965)}}</ref>{{rp|9–10}} Prior to that, the prevailing system was that of ''personal law'', in which the laws applicable to each individual were dictated by the group to which he or she belonged.<ref name="Yntema"/>{{rp|9–10}} Initially, the mode of this body of law was simply to determine which jurisdiction's law would be most fair to apply; over time, however, the law came to favor more well-defined rules.<ref name="Yntema"/>{{rp|12–13}} These rules were systematically summarized by law professor [[Bartolus de Saxoferrato]] in the middle of the fourteenth century,<ref name="Yntema"/>{{rp|13}} a work that came to be cited repeatedly for the next several centuries.<ref>J.A. Clarence Smith, ''Bartolo on the Conflict of Laws'', 14 American Journal of Legal History 157, 157–60 (1970).</ref>

Later, in the seventeenth century, several Dutch legal scholars, including [[Christian Rodenburg]], [[Paulus Voet]], [[Johannes Voet]], and [[Ulrik Huber]], further expounded the jurisprudence of conflict of laws.<ref name ="Yntema"/>{{rp|20–28}} Their key conceptual contributions were twofold: First, nations are wholly sovereign within their borders and therefore cannot be compelled to enforce foreign law in their own courts.<ref name ="Yntema"/>{{rp|28}} Second, in order for international conflicts of law to work rationally, nations must exercise comity in enforcing others' laws, because it is in their mutual interest to do so.<ref name ="Yntema"/>{{rp|30}}Scholars began to consider ways to resolve the question of how and when formally equal sovereign States ought to recognize each other's authority.<ref name=":0">{{Cite journal |last=Schultz |first=Thomas |date=2019 |title=The History of Comity |url=https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3405341 |journal=Jus Gentium – Journal of International Legal History |volume=4 |issue=2 |pages=35 |via=SSRN}}</ref> The doctrine of [[comity]] was introduced as one of the means to answer these questions.<ref name=":0" /> Comity has undergone various changes since its creation. However, it still refers to the idea that every State is sovereign; often, the most just exercise of one State's authority is by recognizing the authority of another through the recognition and enforcement of another state's laws and judgments.<ref>{{Cite journal |last=Schultz |first=Thomas |date=2019 |title=The History of Comity |url=https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3405341 |journal=Jus Gentium – Journal of International Legal History |volume=4 |issue=2 |pages=36 |via=SSRN}}</ref> Many states continue to recognize the principle of comity as the underpinning of private international law such as in Canada.<ref>Morguard Investments Ltd v De Savoye, [1990] 3 SCR 1077.</ref> In some countries, such as the United States of America and Australia, the principle of comity is written into the State's constitution.<ref>William L. Reynolds & William M. Richman, ''The Full Faith and Credit Clause: A Reference Guide to the United States Constitution'' ([[Praeger Publishing|Praeger]], 2005), p. xvii; Constitution of Australia, chapter 7, section 118.</ref>

In the United States, salient issues in the field of conflict of laws date back at least to the framing of the Constitution. There was concern, for example, about what body of law the newly created federal courts would apply when handling cases between parties from different states<ref name = "Nadelmann">Kurt H. Nadelmann, ''Joseph Story's Contribution to American Conflicts Law: A Comment'', 5 American Journal of Legal History 230, 235 (1961).</ref> (a type of case [[Diversity jurisdiction|specifically assigned to the federal courts]]<ref>[[Article Three of the United States Constitution|U.S. Const. Art. III, §2]].</ref>). Within the first two decades following ratification of the Constitution, over one hundred cases dealt with these issues, though the term ''conflict of laws'' was not yet used.<ref name = "Nadelmann"/>{{rp|235–36}} The Constitution created a "plurilegal federal union" in which conflicts are inherently abundant,<ref name="Symeonides">{{cite book |last1=Symeonides |first1=Symeon |authorlink1=Symeon C. Symeonides |title=Choice of Law |date=2016 |publisher=Oxford University Press |location=Oxford |isbn=9780190496722 |page= |url=https://books.google.com/books?id=KNYdDAAAQBAJ&pg=PA6 |access-date=March 18, 2023}}</ref>{{rp|6}} and as a result, American judges encounter conflicts cases far more often—about 5,000 per year as of the mid-2010s—and have accumulated far more experience in resolving them than anywhere else in the world.<ref name="Symeonides"/>{{rp|10}} 

Alongside domestic developments relating to conflict of laws, the nineteenth century also saw the beginnings of substantial international collaboration in the field. The first international meeting on the topic took place in [[Lima]] in 1887 and 1888; delegates from five South American countries attended, but failed to produce an enforceable agreement.<ref name="Ana Delić">{{cite web| url = https://opil.ouplaw.com/page/Treaties-Montevideo/the-birth-of-modern-private-international-law-the-treaties-of-montevideo-1889-amended-1940| title = Ana Delić, ''The Birth of Modern Private International Law: The Treaties of Montevideo'', Oxford Public International Law}}</ref> The first major multilateral agreements on the topic of conflict of laws arose from the [[First South American Congress of Private International Law]], which was held in [[Montevideo]] from August 1888 to February 1889.<ref name="Ana Delić"/> The seven South American nations represented at the Montevideo conference agreed on eight treaties, which broadly adopted the ideas of [[Friedrich Carl von Savigny]], determining applicable law on the basis of four types of factual relations (domicile, location of object, location of transaction, location of court).<ref name="Ana Delić"/>

Soon after, European nations gathered for a conference in [[The Hague]] organized by [[Tobias Asser]] in 1893.<ref name="Hans van Loon 2007">{{cite web| url = https://www.elevenjournals.com/tijdschrift/hjj/2007/2/HJJ_187-4202_2007_002_002_002.pdf| title = Hans van Loon, ''The Hague Conference on Private International Law'', 2 Hague Justice Journal 75 (2007)}}</ref>{{rp|76}} This was followed by successive conferences in 1894, 1900, and 1904.<ref name="Hans van Loon 2007"/>{{rp|76}} Like their counterparts in Montevideo, these conferences produced several multilateral agreements on various topics within conflict of laws.<ref name= "Hans van Loon 2007"/>{{rp|76–77}} Thereafter, the pace of these meetings slowed, with the next conventions occurring in 1925 and 1928.<ref name="Hans van Loon 2007"/>{{rp|77}} The seventh meeting at The Hague occurred in 1951, at which point the sixteen involved states established a permanent institution for international collaboration on conflict-of-laws issues.<ref name="Hans van Loon 2007"/>{{rp|77}} The organization is known today as the [[Hague Conference on Private International Law]] (HCCH). {{as of|2020|12}}, HCCH includes eighty-six member states.<ref>{{cite web| url = https://www.hcch.net/en/about| title = HCCH, ''About HCCH''}}</ref>

As attention to the field became more widespread in the second half of the twentieth century, the [[European Union]] began to take action to harmonize conflict of laws jurisprudence across its member states. The first of these was the [[Brussels Convention]] agreed in 1968, which addressed questions of jurisdiction for cross-border cases.<ref>{{cite web| url = https://eur-lex.europa.eu/legal-content/EN/ALL/?uri=CELEX%3A41968A0927%2801%29| title = 1968 Brussels Convention on jurisdiction and the enforcement of judgments in civil and commercial matters}}</ref> This was followed in 1980 by the [[Rome Convention (contract)|Rome Convention]], which addressed choice-of-law rules for contract disputes within EU member states.<ref>{{cite web| url = http://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:41998A0126(02):EN:NOT| title = 1980 Rome Convention on the law applicable to contractual obligations| date = August 13, 1998}}</ref> In 2009 and 2010, respectively, the EU enacted the [[Rome II Regulation]] to address choice-of-law in tort cases<ref name="EU_Reg864"/> and the [[Rome III Regulation]] to address choice-of-law in divorce matters.<ref>{{cite web| url = https://eur-lex.europa.eu/LexUriServ/LexUriServ.do?uri=OJ:L:2010:343:0010:0016:EN:PDF| title = COUNCIL REGULATION (EU) No 1259/2010}}</ref>

==Jurisdiction==
One of the key questions addressed within conflict of laws is the determination of when the legislature of a given jurisdiction may legislate, or the court of a given jurisdiction can properly adjudicate, regarding a matter that has extra-jurisdictional dimensions. This is known as ''jurisdiction'' (sometimes subdivided into ''adjudicative jurisdiction'', the authority to hear a certain case, and ''prescriptive jurisdiction'', the authority of a legislature to pass laws covering certain conduct).<ref name = "Ryngaert">Cedric Ryngaert, ''Research Handbook on Jurisdiction and Immunities in International Law'', Chapter 2: The Concept of Jurisdiction in International Law (Alexander Orakhelashvili ed. 2015).</ref>{{rp|57–58}} Like all aspects of conflict of laws, this question is in the first instance resolved by domestic law, which may or may not incorporate relevant international treaties or other supranational legal concepts.<ref name ="Orakhelashvili">Alexander Orakhelashvili, ''Research Handbook on Jurisdiction and Immunities in International Law'', Chapter 1: State Jurisdiction in International Law: Complexities of a Basic Concept (Alexander Orakhelashvili ed. 2015).</ref>{{rp|13–14}} That said, relative to the other two main subtopics of conflicts of law (enforcement of judgements, and choice of law, which are both discussed below), the theory regarding jurisdiction has developed consistent international norms. This is perhaps because, unlike the other subtopics, jurisdiction relates to the particularly thorny question of when it is appropriate for a country to exercise its coercive power at all, rather that merely how it should do so.<ref name="Orakhelashvili"/>{{rp|1–4}}

There are five bases of jurisdiction generally recognized in international law. These are not mutually exclusive; an individual or an occurrence may be subject to simultaneous jurisdiction in more than one place.<ref name="Orakhelashvili"/>{{rp|15, 23}} They are as follows:
* '''Territoriality'''—A country has jurisdiction to regulate whatever occurs within its territorial boundaries. Of all bases of jurisdiction, the territoriality principle garners the strongest consensus in international law (subject to various complexities relating to actions that did not obviously occur wholly in one country).<ref name ="Ryngaert"/>{{rp|55–56}}
* '''Passive personality'''—A country has jurisdiction over an occurrence that harmed its national.<ref>{{cite web| url = https://scholarship.law.edu/cgi/viewcontent.cgi?article=1410&=&context=scholar&=&sei-redir=1&referer=https%253A%252F%252Fscholar.google.com%252Fscholar%253Fhl%253Den%2526as_sdt%253D0%25252C5%2526q%253Dpassive%252Bpersonality%252Bprinciple%2526btnG%253D%2526oq%253Dpassive%252Bpersonali#search=%22passive%20personality%20principle%22| title = Geoffrey R. Watson, ''The Passive Personality Principle'', 28 Texas International Law Journal 1, 2}}</ref>
* '''Nationality (or active personality)'''—A country has jurisdiction over a wrong of which its national is the perpetrator.<ref>[https://scholarship.law.edu/cgi/viewcontent.cgi?article=1410&=&context=scholar&=&sei-redir=1&referer=https%253A%252F%252Fscholar.google.com%252Fscholar%253Fhl%253Den%2526as_sdt%253D0%25252C5%2526q%253Dpassive%252Bpersonality%252Bprinciple%2526btnG%253D%2526oq%253Dpassive%252Bpersonali#search=%22passive%20personality%20principle%22 Geoffrey R. Watson, ''Offenders Abroad: The Case for Nationality-Based Criminal Jurisdiction'', 17 Yale Journal of International Law 42].</ref>
* '''Protective'''—A country has jurisdiction to address threats to its own security (such as by pursuing counterfeiters of official documents).<ref name="Stigall">Dan E. Stigall, ''International Law and Limitations on the Exercise of Extraterritorial Jurisdiction in U.S. Domestic Law'', 35 Hastings International & Comparative Law Review 323, 334 (2012).</ref>
* '''Universal'''—A country has jurisdiction over certain acts based on their intrinsic rejection by the international community (such as violent deprivations of basic human rights). This is the most controversial of the five bases of jurisdiction.<ref name = "Stigall"/>

Countries have also developed bodies of law for adjudicating jurisdiction disputes between subnational entities. For example, in the United States, the [[minimum contacts]] rule derived from the [[Due Process Clause]] of the [[Fourteenth Amendment to the United States Constitution|Fourteenth Amendment]] to the U.S. Constitution regulates the extent to which one state can exercise jurisdiction over people domiciled in other states, or occurrences that took place in other states.

==Choice of law==
Courts faced with a choice of law issue have a two-stage process:

#the court will apply the law of the forum (''[[lex fori]]'') to all procedural matters (including the choice of law rules); 
#it counts the factors that connect or link the legal issues to the laws of potentially relevant states and applies the laws that have the greatest connection, e.g. the law of nationality (''[[lex patriae]]'') or the law of [[habitual residence]] (''[[lex domicilii]]''). (See also 'European Harmonization Provisions': "The concept of habitual residence is the civil law equivalent of the common law test of lex domicilii".) The court will determine the plaintiffs' legal [[status (law)|status]] and [[capacity (law)|capacity]]. The court will determine the law of the state in which land is situated (''[[lex situs]]'') that will be applied to determine all questions of [[title (property)|title]]. The law of the place where a transaction physically takes place or of the occurrence that gave rise to the litigation (''lex loci actus'') will often be the controlling law selected when the matter is substantive, but the [[proper law]] has become a more common choice.<ref>[http://www7.austlii.edu.au/cgi-bin/viewdoc/au/cases/cth/HCA/2002/56.html?context=1;query=dow%20jones;mask_path=au/cases/cth/HCA# ''Dow Jones and Company Inc v Gutnick'' [2002] HCA 56; 210 CLR 575; 194 ALR 433; 77 ALJR 255 (10 December 2002).]</ref>

===Contracts===
Many [[contract (conflict)|contracts]] and other forms of legally binding agreement include a jurisdiction or [[arbitration]] clause specifying the parties' choice of venue for any litigation (called a [[forum selection clause]]). In the EU, this is governed by the [[Rome I Regulation]]. [[Choice of law clause]]s may specify which laws the court or tribunal should apply to each aspect of the dispute. This matches the substantive policy of [[freedom of contract]] and will be determined by the law of the state where the choice of law clause confers its competence. Oxford Professor Adrian Briggs suggests that this is doctrinally problematic as it is emblematic of 'pulling oneself up by the bootstraps'.<ref>Adrian Briggs, The Conflict of laws, Clarendon Law Series third edition 2013.</ref>

Judges have accepted that the principle of party autonomy allows the parties to select the law most appropriate to their transaction. This judicial acceptance of subjective intent excludes the traditional reliance on objective connecting factors;<ref>Rome I Regulation, Article 3(1). See also ''Macmillan v Bishopsgate Investment Trust plc'' [1996] 1 WLR 387 per Staughton LJ 391–392; ''Golden Ocean Group v Salgocar Mining Ltd'' [2012] EWCA Civ 542.</ref> it also harms consumers as vendors often impose one-sided contractual terms selecting a venue far from the buyer's home or workplace. Contractual clauses relating to consumers, employees, and insurance beneficiaries are regulated under additional terms set out in [[Rome I]], which may modify the contractual terms imposed by vendors.<ref>Rome I Regulation, Articles 5-8</ref>

==See also==
{{Portal|Law}}
*[[A. V. Dicey]]
*[[Comity]]
*[[List of Hague Conventions on Private International Law]]
*[[Place of the Relevant Intermediary Approach]]
*''[[Microsoft Corp. v. Motorola Inc.]]''

==Notes==
{{Reflist|30em}}

==References and further reading==
*{{cite book |last=Cherednychenko |first=Olha |title=Fundamental Rights, Contract Law, and Protection of the Weaker Party |date=2007 |publisher=Utrecht University Institute for Legal Studies |location=Utrecht, Netherlands |hdl=1874/20945 }}
*{{Cite book |editor=American Law Institute |editor-link=American Law Institute |title=Restatement of the Law, Second: Conflict of Laws |place=St. Paul}}
*{{Cite book |last=Briggs |first=Adrian |title=The Conflict of Laws |edition=Second |place=Oxford |publisher=Oxford University Press |year=2008}}
*{{Cite book |first=Gary |last=Born |author-link=Gary Born |title=International Commercial Arbitration |year=2009 |publisher=Kluwer}}
*{{Cite book |first=Gralf-Peter |last=Calliess |title=The Rome Regulations: Commentary on the European Rules of the Conflict of Laws |year=2010 |publisher=Kluwer}}
*CILE Studies (Center for International Legal Education – [[University of Pittsburgh School of Law]]) [https://web.archive.org/web/20080828014708/http://www.law.pitt.edu/academics/cile/publications/books/contents2 Private Law, Private International Law, and Judicial cooperation in the EU-US Relationship].
*{{Cite book |last1=Clarkson |first1=C.M.V. |last2=Hill |first2=Jonathan |title=The Conflict of Laws |edition=Third |publisher=Oxford University Press |location=Oxford |year=2006}}
*{{Cite book |editor1=Collins, Lawrence|editor1-link=Lawrence Collins, Baron Collins of Mapesbury|editor2=Harris, Jonathan|editor2-link=Jonathan Harris (barrister)|title=[[Dicey Morris & Collins|Dicey Morris and Collins on The Conflict of Laws]] |edition=Fifteenth |publisher=[[Sweet & Maxwell]] |place=London |year=2017}}
*{{Cite book |last1=Hay |first1=Peter |last2=Borchers |first2=Patrick J. |last3=Symeonides |first3=Symeon C. |title=Conflict of Laws |edition=Fifth |publisher=West |place=St. Paul, Minn. |year=2010}}
*{{Cite book |last1=McClean |first1=David |last2=Beevers |first2=Kisch |title=The Conflict of Laws |edition=Seventh |publisher=Sweet & Maxwell |place=London |year=2009}}
*{{Cite book |last1=North |first1=Peter |author-link1=Peter North (academic) |last2=Fawcett |first2=J.J. |year=1999 |title=Cheshire and North's Private International Law |edition=13th |place=London |publisher=Butterworths}}
*{{Cite book |last=Reed |first=Alan |year=2003 |title=Anglo-American Perspectives on Private International Law |place=Lewiston, N.Y. |publisher=E. Mellen Press}}
*{{Cite book |last=Rogerson |first=Pippa |author-link=Pippa Rogerson |title=Collier's Conflicts of Laws |edition=Fourth |publisher=Cambridge University Press |place=Cambridge |year=2013}}
*{{Cite book |last=Symeonides |first=Symeon C. |author-link=Symeon C. Symeonides |title=American Private International Law |publisher=Wolters Kluwer |year=2008}}

==External links==
*[https://web.archive.org/web/20060402193511/http://comparativelaw.org/ American Society of Comparative Law Official website]
*[https://web.archive.org/web/20060314231951/http://www.asil.org/resource/pil1.htm ASIL Guide to Electronic Resources for International Law]
*[https://web.archive.org/web/20101112155647/http://www.biicl.org/private_international_law/herbert_smith_seminar_series/ British Institute of International and Comparative Law]
*[https://web.archive.org/web/20200220033050/http://conflictoflaws.net/ CONFLICT OF LAWS.NET] – News and Views in Private International Law
*[https://web.archive.org/web/20071007100825/http://www.rome-convention.org/instruments/i_conv_cons_en.htm EEC Rome convention 1980]
*[https://web.archive.org/web/20101222015746/http://www.eiil.eu/en/component/content/article/84.html European Institute for International Law and International Relations]
*[http://www.hcch.net/ Hague Conference on Private International Law]
*[https://web.archive.org/web/20100306070926/http://www.lexisnexis.com/Community/international-foreignlaw/landing-page.aspx?Item=333 International & Foreign Law Community]
*[http://www.iccwbo.org/ International Chamber of Commerce]
*[https://web.archive.org/web/20100612202850/http://iccwbo.org/policy/arbitration/id2882/index.html International Court of Arbitration]
*[https://web.archive.org/web/20050820161131/http://www.unidroit.org/ International Institute for the Unification of Private Law] (UNIDROIT)
*[[Max Planck Society|Max Planck Institute]] – [https://web.archive.org/web/20200505055615/https://www.mpipriv.de/ for Comparative and International Private Law]
* [http://www.peacepalacelibrary.nl/research-guides/national-law/private-international-law-in-general/ Private International Law, Research Guide] {{Webarchive|url=https://web.archive.org/web/20161103215614/http://www.peacepalacelibrary.nl/research-guides/national-law/private-international-law-in-general/ |date=November 3, 2016 }}, [[Peace Palace Library]]
*''Republic of Argentina v NML Capital Ltd'' [2010] [http://www.bailii.org/ew/cases/EWCA/Civ/2010/41.html EWCA Civ 41], regarding a hedge fund's enforcement of claim against [[Argentina]]
*[https://web.archive.org/web/20050813075308/http://www.uncitral.org/ United Nations Commission for International Trade Law]
*[[United States Department of State|U.S. State Department]] [https://2009-2017.state.gov/s/l/c3452.htm Private International Law Database]
*[https://web.archive.org/web/20031230180358/http://writ.news.findlaw.com/scripts/printer_friendly.pl?page=%2Fcommentary%2F20010927_sprigman.html ''Why the Hague Convention on jurisdiction threatens to strangle e-commerce and Internet free speech''], by Chris Sprigman

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[[Category:Conflict of laws| ]]