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National Repository of Grey Literature 2 records found  Search took 0.00 seconds. 
Governing law in the absence of choice in contractual relations in the Czech Republic and in the United States (private international law in a comparative perspective)
 Chvosta, Ondřej ; Pauknerová, Monika (advisor) ; Růžička, Květoslav (referee)
Governing Law in the Absence of Choice in Contractual Relations in the Czech Republic and in the United States (Private international law in a comparative perspective) English Summary: The subject of the thesis is the main differences in Private International Law (or Conflict of Laws in the Unites States) in the area of contractual relations in the absence of a choice of law. The introduction explains the methodology of the work, as it does not strive to provide an exhaustive list of contract types - since this would be ill-advised considering the differences in Czech and American contract law - but rather provide the reader with a general characterization of the different approaches to the subject matter. The introduction also explains the legal certainty principle (typical for Civil Law countries) and the principle of equity (typical for Common Law countries), and describes how the consideration of these will enhance the reader's understanding of the thesis' topics. The first chapter is concerned with the relevant sources of law in the Czech Republic and in the United States. The most important legislation applicable in the Czech Republic is the Czech Private International Law Act, the Rome Convention and the Rome I Regulation. In relation to US law, the text discusses some of the most important clauses...
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Governing law in the absence of choice in contractual relations in the Czech Republic and in the United States (private international law in a comparative perspective)
 Chvosta, Ondřej ; Pauknerová, Monika (advisor) ; Růžička, Květoslav (referee)
Governing Law in the Absence of Choice in Contractual Relations in the Czech Republic and in the United States (Private international law in a comparative perspective) English Summary: The subject of the thesis is the main differences in Private International Law (or Conflict of Laws in the Unites States) in the area of contractual relations in the absence of a choice of law. The introduction explains the methodology of the work, as it does not strive to provide an exhaustive list of contract types - since this would be ill-advised considering the differences in Czech and American contract law - but rather provide the reader with a general characterization of the different approaches to the subject matter. The introduction also explains the legal certainty principle (typical for Civil Law countries) and the principle of equity (typical for Common Law countries), and describes how the consideration of these will enhance the reader's understanding of the thesis' topics. The first chapter is concerned with the relevant sources of law in the Czech Republic and in the United States. The most important legislation applicable in the Czech Republic is the Czech Private International Law Act, the Rome Convention and the Rome I Regulation. In relation to US law, the text discusses some of the most important clauses...
Detailed record

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