The European Magnet and the U.S. Centrifuge: Ten Selected Private International Law Developments of 2008

Abstract

This article considers ten developments in private international law that occurred in 2008. In doing so, it focuses on the way in which these developments demonstrate a parallel convergence of power for private international in the institutions of the European Community and dispersal of power for private international law in the United States. This process carries with it important implications for the future roles of both the European Union and the United States in the multilateral development of rules of private international law, with the EU moving toward an enhanced leadership role and the United States restricting its own ability to continue in to exert leadership.

Keywords: private international law, conflict of laws, choice of law, Rome Convention, Rome Regulation, European Court of Justice, CISG, Medell¿n, Hall Street, forum non conveniens, Hague Convention on Choice of Court Agreements, Uniform Law Commission