United States: Fourth (and Final?) Act In The Kabab-Ji Saga—What Law Governs The Arbitration Agreement (Law Of The Seat Or Law Of The Underlying Contract)? - Akin Gump Strauss Hauer & Feld LLP
On 28 September 2022, the French Cour de cassation1 upheld the French Court of Appeal's decision in Kabab-Ji SAL v. Kout Food Group that the law of the seat, rather than the law governing...
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