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The adoption of electronic commercial transactions has facilitated cross-border trade and business, but the complexity of determining the place of business and other connecting factors in cyberspace has challenged existing private international law. This comparison of the rules of Internet jurisdiction and choice of law as well as online dispute resolution (ODR) covers both B2B and B2C contracts in the EU, US and China. It highlights the achievements of the Brussels I and Rome I Regulation in the EU, evaluates the merits of the Hague Convention on Choice of Court Agreements at the international level and gives an insight into the current developments in CIDIP. The in-depth research allows for solutions to be proposed relating to the problems of legal uncertainty of Internet conflict of law and the validity and enforceability of ODR agreements and decisions.
Conflict of laws --- Online dispute resolution --- Electronic commerce --- ODR (Online dispute resolution) --- Dispute resolution (Law) --- Choice of law --- Intermunicipal law --- International law, Private --- International private law --- Private international law --- Law --- Legal polycentricity --- Law and legislation --- Civil law --- Conflict of laws - Electronic commerce - China --- Conflict of laws - Electronic commerce - European Union countries --- Conflict of laws - Electronic commerce - United States --- Online dispute resolution - China --- Online dispute resolution - United States --- Online dispute resolution - European Union countries --- Etats-Unis --- Chine --- General and Others --- Commerce électronique (Droit international privé) --- Règlement de conflits en ligne --- Comparative law --- Droit comparé
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