BUSINESS & TECHNOLOGY CONTRACTING

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US Choice of Law Provisions in International Agreements

    This practice note explains why New York and Delaware law are most commonly selected as governing law in international commercial agreements involving U.S. parties, emphasizing their predictability, neutrality, and well‑developed legal frameworks. It highlights the strategic considerations for foreign companies when choosing between these jurisdictions, including enforceability, investor expectations, and sector‑specific needs.

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    European Choice of Law Provisions in International Agreements

      This practice note examines how European choice of law provisions operate in international contracts, with a focus on the Rome I Regulation and its impact on party autonomy, default rules, and mandatory protections. It highlights key differences among European jurisdictions and offers practical guidance for negotiators seeking predictability and enforceability in cross-border agreements.

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      Asian and Far East Choice of Law Provisions in International Agreements

        This practice note explains that in international agreements involving Asian and Far Eastern counterparties, parties often choose English, Singapore, or Hong Kong law for their neutrality, predictability, and strong dispute resolution frameworks. Local laws (such as Chinese, Japanese, or Korean law) are selected mainly when regulatory compliance or domestic enforcement is critical, while English, Singapore, and Hong Kong law are preferred for commercial clarity and regional enforceability.

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        Comparing Common Law Systems vs. Civil Law Systems for International Agreements

          This practice note compares common law and civil law systems, highlighting how their differences impact international agreements, especially intellectual property licence arrangements. It concludes that common law jurisdictions are generally preferred for cross-border IP deals due to their predictability, flexibility, and strong enforcement mechanisms, while civil law systems may be chosen for regional familiarity or cost efficiency.

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          Top Destinations for International Arbitration

            This practice note provides an overview of the world’s leading venues for international arbitration, examining their legal frameworks, institutional support, and strategic factors influencing venue selection. It aims to help practitioners, in-house counsel, and parties to international contracts understand the nuances of different arbitration jurisdictions for effective cross-border dispute resolution.

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            International Arbitration in South Africa: Framework, Strengths and Global Comparisons

              This practice note examines South Africa’s international arbitration regime under the International Arbitration Act 2017, focusing on its alignment with the UNCITRAL Model Law, the role of domestic courts, and the development of key institutions such as AFSA. It further situates South Africa within the global arbitration landscape by comparing its legal framework, institutional strength, and practical advantages with established seats including London, Singapore, and Switzerland, with particular emphasis on its role as a regional hub for African disputes.

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