Choice of Law Rules Sample Clauses

Choice of Law Rules. 4.1 How is the law applicable to the substance of a dispute determined? Unless the parties have agreed on the governing law, the tribunal will decide what country’s substantive law is applicable to the substance of the dispute.
Choice of Law Rules. 3078 CCQ  Discusses the “characterization” of property as moveable or immoveable. Determine the law of the place where the property is situated. May be difficult b/c material may be bounced around & in pieces through out various legal jurisdictions. 3097 CCQ  Real rights & their publication are governed by the law of the place where the property is situated. Third paragraph states, however, that where materials are in transit then they are governed by the law of the place of their destination. I.e. if the destination of X-material is Montreal then the real rights in connection w/ that property will be determined by QC law. 3102 CCQ  Moveable security validity is determined by the law of the country of which (1) the property is charged with at the time of creation & (2) publication of effects thereof are determined where the property is now situated. 3105 CCQ  Validity of security on a movable corporeal security ordinarily used in more than one country or charged on an incorporeal movable (i.e. CR or claims) may be governed by the law of the country where the grantor is domiciled Meaning where the producer of the film is domiciled – hence if he lives in QC & is granting security in corporeal or incorporeal objects that is ordinarily used in more than one country QC law will apply. Americans have problems with this, they also want to make sure that American laws will also respect their security in X-corporeal or incorporeal objects, regardless if QC “should” apply or not. “Play it safe! Especially if you’re the bank – ensure you have security that will be recognized regardless of the court’s decision what is the proper law!” Screenplay CR Security Plan: [U.S.] First thing to do when producing a film is to ensure that US CR has been registered in the CR office & if it was not a WMFH then secondly one must record that CR is to vest in the producer. Thirdly, there must be a grant of security in favour of the bank that is called a recordation in the CR office in the U.S. You would however still register under the UCC in the US to ensure that security is valid. This is vital [see Peregine Entertainment]! [Q.C.] Where QC the producer is domiciled in QC, 3105 CCQ will be relevant & there will be a hypothec used (real right in the property – right in rem). R. to follow, take the property in paymentsubject to Rs of 3Ps. R to cause the property to be sold judicially, where the parties would then line up to collect proceeds of the sale – of which disposi...
Choice of Law Rules. 4.1 How is the law applicable to the substance of a dispute determined? The law applicable to the substance of the dispute is determined by the parties. However, if the parties abstained to make any selection, Qatari law shall apply when the arbitration is sited in Qatar (cf. Art. 198 of the Code of Civil and Commercial Procedure: if it is agreed to hold the arbitration in Qatar, the laws of the State of Qatar shall be applicable to all elements of the dispute, unless otherwise agreed by the parties). The parties may authorise the arbitrators to rule in equity (amiable composition), provided that the latter do not contravene the Qatari rules of public policy (Art. 198). Under the QICCA rules and the QFC arbitration regulations, failing any designation by the parties, the arbitral tribunal shall apply the law determined by the conflict of laws rules which it considers applicable.
Choice of Law Rules. 4.1 How is the law applicable to the substance of a dispute determined? The law applicable to the substance of the dispute is determined by the parties. In the absence of an express choice, the arbitral tribunal will determine the applicable substantive law on the basis of the relevant rules of private international law (e.g. those laid down in EU Regulation Rome I).

Related to Choice of Law Rules

  • Choice of Laws 9.1 This Waiver and Release and the rights and obligations of the parties hereto shall be governed and construed in accordance with the laws of the State of New York.

  • Choice of Law THIS AGREEMENT SHALL BE GOVERNED BY AND CONSTRUED IN ACCORDANCE WITH THE INTERNAL, SUBSTANTIVE LAWS OF THE STATE OF NEW YORK WITHOUT REFERENCE TO THE RULES THEREOF RELATING TO CONFLICTS OF LAW, OTHER THAN SECTIONS 5-1401 AND 5-1402 OF THE NEW YORK GENERAL OBLIGATIONS LAW, AND THE OBLIGATIONS, RIGHTS AND REMEDIES OF THE PARTIES HEREUNDER SHALL BE DETERMINED IN ACCORDANCE WITH SUCH LAWS.

  • Choice of Law; Venue This Agreement shall be governed by the laws of the State of Texas. Venue and jurisdiction of any suit or cause of action arising under or in connection with the Agreement shall lie exclusively in Harris County, Texas. Disputes between END USER and Contractor are to be resolved in accordance with the law and venue rules of the state of purchase. Contractor shall immediately notify H-GAC of such disputes.

  • Choice of Law; Jurisdiction This Agreement and all claims, causes of action or proceedings (whether in contract, in tort, at law or otherwise) that may be based upon, arise out of or relate to this Agreement will be governed by the internal laws of the State of Delaware, excluding any conflicts or choice-of-law rule or principle that might otherwise refer construction or interpretation of this Agreement to the substantive law of another jurisdiction. The Participant and each party to this Agreement agrees that it will bring all claims, causes of action and proceedings (whether in contract, in tort, at law or otherwise) that may be based upon, arise out of or be related to the Plan and this Agreement exclusively in the Delaware Court of Chancery or, in the event (but only in the event) that such court does not have subject matter jurisdiction over such claim, cause of action or proceeding, exclusively in the United States District Court for the District of Delaware (the “Chosen Court”), and hereby (i) irrevocably submits to the exclusive jurisdiction of the Chosen Court, (ii) waives any objection to laying venue in any such proceeding in the Chosen Court, (iii) waives any objection that the Chosen Court is an inconvenient forum or does not have jurisdiction over any party and (iv) agrees that service of process upon such party in any such claim or cause of action will be effective if notice is given in accordance with this Agreement.

  • CHOICE OF LAW & FORUM The state courts of Wisconsin shall be the sole forum for all disputes arising of this Contract. The validity, construction, enforcement and effect of this Contract shall be governed solely by the laws of the State of Wisconsin.

  • Choice of Law; Arbitration (a) Notwithstanding the place where this Agreement may be executed by any of the parties hereto, the parties expressly agree that all the terms and provisions hereof shall be construed under the laws of the State of Delaware, including the Delaware Act without regard to the conflict of law principles of such State.

  • Choice of Law and Venue (a) THE VALIDITY OF THIS AGREEMENT AND THE OTHER LOAN DOCUMENTS (UNLESS EXPRESSLY PROVIDED TO THE CONTRARY IN ANOTHER LOAN DOCUMENT IN RESPECT OF SUCH OTHER LOAN DOCUMENT), THE CONSTRUCTION, INTERPRETATION, AND ENFORCEMENT HEREOF AND THEREOF, AND THE RIGHTS OF THE PARTIES HERETO AND THERETO WITH RESPECT TO ALL MATTERS ARISING HEREUNDER OR THEREUNDER OR RELATED HERETO OR THERETO SHALL BE DETERMINED UNDER, GOVERNED BY, AND CONSTRUED IN ACCORDANCE WITH THE INTERNAL LAWS OF THE STATE OF CALIFORNIA, WITHOUT REGARD FOR PRINCIPLES OF CONFLICTS OF LAWS.

  • Choice of Law; Choice of Forum This Agreement shall be interpreted in accordance with and governed by the Law of the State of New York. The courts of the State of New York and the United States District Court for the Southern District of New York shall have exclusive jurisdiction to settle any Claim. Each Party submits to the exclusive jurisdiction of such courts and waives to the fullest extent permitted by Law all rights to a trial by jury.

  • Choice of Law and Jurisdiction California law, without regard to its choice-of-law provisions, governs this Agreement. The parties shall attempt in good faith to resolve informally and promptly any dispute that arises under this Agreement. Jurisdiction for any legal action arising from this Agreement shall exclusively reside in state or federal courts located in California, and the parties hereby consent to the jurisdiction of such courts.

  • Choice of Law; Severability This Lease shall in all respects be governed by and construed in accordance with the laws of the State of California. If any provision of this Lease shall be invalid, unenforceable or ineffective for any reason whatsoever, all other provisions hereof shall be and remain in full force and effect.