CISG Opt-Outs and Ascertaining Party Intent: A Back-to-Basics Perspective
Two of this year’s contributions to Transnational Litigation Blog have addressed the intellectually stimulating but also practically pressing issue of identifying when, and how, commercial parties can exclude the United Nations Convention on Contracts for the International Sale of Goods from their international sales agreements. In Professor John Coyle’s CISG Opt-Outs and Party Intent, Professor…
Continue ReadingRewarding Ignorance of the CISG: A Response to John Coyle
In a recent post, Professor John Coyle considers the interpretation of the following choice of law (“COL”) clause in an international contract for sale of goods where both parties are located in Contracting States to the U.N. Convention on Contracts for the International Sale of Goods (CISG): “This Agreement shall be governed by the laws…
Continue ReadingCISG Opt-Outs and Party Intent
The United Nations Convention on Contracts for the International Sale of Goods (CISG) is one of the most widely adopted commercial law treaties in the world. It functions as an “international” version of Article 2 of the Uniform Commercial Code (UCC) and, as such, provides the governing law for many cross-border agreements involving the sale…
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