This book deals with set-off in international arbitration proceedings. In these proceedings, set-off is frequently the tool relied upon to resist a claim. At the same time, the legal intricacies make it hard to use. The first part of the book provides a survey of set-off, including its definition, significance, and functions. The second part offers a thorough comparative analysis of selected European laws of set-off and reveals the dramatic differences between them. The third and final part of the book deals with the problematic consequences of these differences and shows the limits and the inadequacy of the traditional choice-of-law doctrines. While demonstrating how to overcome the practical hurdles of the present situation, the third part also offers normative alternatives that may offer significant help in the adjudication of commercial disputes. This will be an invaluable reference for arbitration and commercial practitioners.

Written for international trade lawyers, practitioners and students from common law and civil law countries, this casebook will help practitioners and students assimilate knowledge on the CISG. The cases, texts and questions aid readers in their comparative law and international sales law studies, drawing attention to the particular issues surrounding specific CISG provisions and provoking careful consideration of possible solutions. In addition to this book's function as a didactical aid, it is a reference work for leading cases and an introduction to the individual problem areas. In particular, it acts as a preparatory and complementary work for the Willem C. Vis International Commercial Arbitration Moot.

Written for international trade lawyers, practitioners and students from common law and civil law countries, this casebook will help practitioners and students assimilate knowledge on the CISG. The cases, texts and questions are intended to aid readers in their comparative law and international sales law studies, and are designed to draw attention to the particular issues surrounding specific CISG provisions and to provoke careful consideration of possible solutions. In addition to this book's function as a didactical aid, it is a reference work for leading cases and an introduction to the individual problem areas. In particular, it acts as a preparatory and complementary work for the Willem C. Vis International Commercial Arbitration Moot.

This is the third edition of the casebook providing an article-by-article analysis of the CISG Convention. Offering a fully updated range of materials, this casebook is an excellent starting point for learning about the Convention and will be particularly useful for international trade lawyers, practitioners and students. The commentary on each article is accompanied by extracts from cases and associated comparative materials, as well as references to important trade usages such as the INCOTERMS (R) 2010. The book features an updated selection of the most significant cases, each of which has been abridged to enable the reader to focus on its essential features and the relevant questions arising from it. The case extracts are accompanied by a comprehensive overview of parallel provisions in other international instruments, uniform projects and domestic laws. The analyses, cases, texts and questions are intended to aid readers in their comparative law and international sales law studies. They are designed to draw attention to the particular issues surrounding specific CISG provisions and to provoke careful consideration of possible solutions. The book is a reference work as well as an introduction to the individual problem areas. In particular, it acts as a preparatory work for the Willem C Vis International Commercial Arbitration Moot. Sample questions and answers are also included, which make it particularly helpful for self-study purposes.