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The Rome II Regulation — A short analysis of Article 4

5 december, 2010

I suspect the following might be appreciated by more than just Swedish readers, so therefore this blog post is in English (the same reasoning applies to my other blog posts in English). First of all, a short introduction in Swedish:

Rom II-förordningen skapar ett enhetligt, bindande unionssystem (EU), direkt applicerbart för EU-medborgare. Jag tänkte här behandla den i förordningens fjärde artikel fastslagna huvudregeln om lex loci damni, vilken delvis var ett anammande av en ny princip inom unionsrättens IP-system.

Inledningsvis kanske jag bör förklara att IP-rätt inte är samma sak som IP law (intellectual property law). Förkortningen IP används inom svensk rätt för den s.k. internationella privaträtten. Internationell privaträtt är de rättsregler som, allmänt definierat, styr domstolsjurisdiktion, vilket lands lagar som ska tillämpas på ett aktuellt problem, samt huruvida andra länders domar ska verkställas här i landet. EU-lagstiftaren har sökt harmonisera lagstiftningen i medlemsländerna med egna instrument, främst fem stycken förordningar kallade Bryssel I, Bryssel II, Rom I, Rom II samt insolvensförordningen. Brysselreglerna handlar om i vilka situationer ett visst lands domstolar ska ha jurisdiktion, medan Romreglerna handlar om vilket lands lagar som ska tillämpas i en domstolsprocess.

1 — Introduction

The Rome II Regulation creates a binding and directly applicable, unified and consistent Community system for the determination of applicable law on non-contractual obligations. This text assesses the general rule contained in Article 4 of the Regulation. The special rules on product liability, competition matters, environmental damage, intellectual property rights, industrial actions, unjust enrichment, negotiorum gestio and culpa in contrahendo will not be treated.

Article 4 establishes the concept of lex loci damni as the general rule, stepping away from older European Private International law instruments in some regards, and keeping in line with certain case-law in others.

The instrument itself has not yet generated any case-law, but the case Deo Antoine Homawoo v GMF Assurances SA, C-412/10, about the temporal scope of the Regulation, is waiting to be decided by the ECJ. This means that interpretations of some of the phrases and concepts in the Regulation are, at best, educated guesses. However, it can nonetheless safely be said that case-law on certain other instruments is likely to provide probable interpretative guidance.

Unless otherwise noted, lex loci delicti commissi in this text refers to the law of the place where the event giving rise to the damage occurred, i.e. the contrasting forum to the lex loci damni, the law of the place where the damage occurred. Lex loci delicti commissi, often shortened to lex loci delicti, also denotes the law of the place where the harmful event occurred, which, according to the European Court of Justice, can be treated as a sort of ‘meta-concept’ in which both the law of the place where event giving rise to the damage occurred, and the law of the place where the damage occurred, are included.

2 — Background

The Rome II Regulation became applicable from 11 January 2009, to events giving rise to damage which occurs after 20 August 2007, according to Articles 31 and 32.

In its Draft programme of measures for implementation of the principle of mutual recognition of decisions in civil and commercial matters, the Council suggested that increased European harmonization in the area of private international law was needed. By harmonizing the laws on applicable law, decisions would gain in foreseeability, and thus in legitimacy, across the Union (see recitals 4 and 16 of the Rome II Regulation).

The Brussels I Regulation and its predecessor the Brussels Convention created a doctrine, wherein a claimant in certain situations would be allowed to choose a forum for his claim. As different Member States adhered to different rules on applicable law, this forum shopping led to less foreseeability concerning the outcome of individual cases, and could potentially have caused distortions in competition between companies from different Member States. The objective of Rome II was to rectify this, with the added benefits of increased legal certainty and lower litigation costs.

Granted that almost all Member States previously applied lex loci delicti commissi, the ‘meta-concept’, situations where the component factors of a single cause were spread over several different Member States still generated uncertainty as to the applicable law.

2.1 — Scope

The substantive scope of the Regulation should be consistent with the Brussels I Regulation, and the nature of the court or tribunal shall not affect the application of the Regulation (see recitals 7 and 8).

The Regulation is applicable to non-contractual obligations. According to recital 11,  this is to be treated as an autonomous concept. Based on recital 7 and the special relationship to the Brussels rules, case-law from the European Court of Justice, on the delimitation between Article 5(1) and 5(3) in Brussels I, will serve as a guide in determining whether a certain obligation is contractual or non-contractual according to Rome II. (Bogdan, p. 930) Included in the Rome II Regulation are, however, torts (delicts), acts of unfair competition, infringements of intellectual property rights, unjust enrichment, negotiorum gestio, and culpa in contrahendo.

Article 1 states that the Regulation shall not be applicable to administrative matters or State actions, so-called acta iure imperii. The second paragraph lists seven specific matters excluded from the application of the Regulation. Subparagraph (g) is worth mentioning, excluding from application violations of privacy and rights relating to personality, including defamation. This exclusion is due to political disagreement between the Member States on the concept of freedom of speech. (Bodgan, p. 931) This might be considered unfortunate, due to the increasing importance of having a clear-cut set of rules for behavior on the Internet.

The Regulation is also applicable to non-contractual obligations that are likely to arise in the future.

2.2 — Peculiarities

2.2.1 — Universal application

The law specified in the Regulation shall be applied whether or not it is the law of a Member State, which is consistent with the rules in the Rome I Regulation on applicable law on contractual obligations.

2.2.2 — Choice of law

The parties may, under the Regulation, choose the law to be applied. They may do this by agreement after the event giving rise to the damage, and, if the parties are pursuing a commercial activity (Seems to include one-sided relationships, such as those arising from franchise, licensing, or insurance contracts. See Symeonides, p. 220), by a freely negotiated agreement before such an event; they may not do this in cases of unfair competition or infringements of intellectual property rights. The parties may decide that the law applicable shall be the law of a country with no connecting factors to the obligation, but, in cases where all the elements relevant to the situation are located in a country other than the chosen one, must accept mandatory rules in that country. The same is stated for mandatory Community rules where the relevant elements are located in a Member State. The choice of applicable law does not bind third parties.

The choice must be expressed or demonstrated with reasonable certainty by the circumstances of the case. The Regulation is silent about which law to apply to choices of law according to Article 14, and also about whether the parties may choose different laws to be applied to different parts of the obligation, so-called dépeçage. Analogous interpretation from the Rome I Regulation would say that, for the question on which law to apply to the agreement on a choice of law, the law of the country agreed upon if the agreement were to be valid shall be used. Dickinson states that dépeçage is permitted under the Regulation only to the extent that it is mandated or permitted under Chapter V or as a result of the exclusion of matters of evidence and procedure. It is not allowed under Article 4(2) and (3). (Dickinson 2, p. 355)

2.2.3 — The concept of ‘country’

Article 25 states that, ”[w]here a State comprises several territorial units, each of which has its own rules of law in respect of non-contractual obligations, each territorial unit shall be considered as a country for the purposes of identifying the law applicable …”. Non-contractual obligations must be assumed to be the same concept as used in the Regulation at large (Hartley, p. 901), thus including unjust enrichment, negotiorum gestio and culpa in contrahendo. The Article is silent on what would happen when such a territorial unit has its own rules on only some of those matters but not others.

3 — Article 4

Article 4 of the Rome II Regulation consists of three paragraphs. The first one is the main rule, the second one provides an exception to said rule, and the third one is an escape clause. The Article is subsidiary to the rest of the Regulation, however, this creates issues itself. For instance, recital 21 states that Article 6 is, rather than an exception, a clarification of the general rule in Article 4(1). What is meant by this is unclear. (Dickinson 2, p. 300) These issues will not be touched upon here.

3.1 — Paragraph 1

The main rule is, as has previously been stated, lex loci damni, the law of the country in which the damage occurs, irrespective of the country in which the event giving rise to the damage occurred (The explicit inclusion of this is to ensure that the rule in Bier applies also with regard to choice of law, see Hartley, p. 899) and irrespective of the country or countries in which the indirect consequences of that event occur (And the explicit inclusion of this is to ensure that the rule in Dumez and Marinari applies).

Lex loci damni was considered to strike a fair balance between the interests of the alleged liable person and the person sustaining the damage. Recital 16 describes it as reflecting the modern approach to civil liability and the development of systems of strict liability. Lex loci delicti commissi, the law of the country where the harmful event occured, used in most Member States, was considered too uncertain as a main rule in cross-border situations. Lex loci damni should in most cases correspond to the law of the injured party’s country of residence.

The Brussels I Regulation states in its Article 5(3) that the courts in the country where the harmful event occurred shall have jurisdiction in matters relating to tort, delict or quasi-delict. The ECJ divided this into two parts: the country where the event giving rise to the damage occurred, and the country where the damage occurred. It was decided in Bier that the claimant may choose between these two, whichever suits him best, but if he chooses the latter country, the claim may only cover the damage sustained in that country. (cf. Shevill v Presse Alliance, C-68/93)

Concerning Rome II, a right to choose applicable law is denied the claimant by the very choosing of lex loci damni. This means that a court in the country where the damage was sustained will apply its own law (lex fori), and only on damage sustained in that country, while a court in the country where the event giving rise to the damage occurred has jurisdiction over damage sustained in any country, but will apply foreign law.

Article 4(1) gives preference to the purpose of compensating the person sustaining damage (reparation) as against the purpose of hindering or preventing certain tortious behavior (deterrence). That the causer of the event giving rise to the damage should be able to reasonably predict the outcomes of his actions by easier determining the applicable law was deemed unimportant. (Koziol and Thiede criticize the rule for focusing solely on the interests of the injured party, and not taking into account the interests of the liable person sufficiently. They argue that lex loci damni instead should be used as an exception to a main rule of lex loci delicti commissi, in situations where the damage could have been foreseen by the liable person, or at the very least, given a main rule of lex loci damni, an exception to this in cases where the damage could not have been foreseen by the liable person.) The Regulation is not limited to actions to obtain compensatory damages, but extends to inter alia claims for injunctive relief to prevent future breaches of non-contractual obligations.

A seller of certain merchandise could suffer severe litigation costs in the event the merchandise causes damage to buyers in multiple countries at the same time. It is worth noting that Article 4(1) rejects two rules which would have a centralizing effect (‘the country in which the event giving rise to the damage occurred’ and ‘the country or countries in which the indirect consequences of that event occur’), and accepts a ‘centrifugal’ one (the lex loci damni). The places where the damage occurs will mostly be far more numerous than the place in which the event giving rise to the damage occurred.

This is an intended consequence of the main rule, following the German legal concept of Mosaikbetrachtung, and generating issues concerning in particular trade secrets. (Wadlow, p. 314) These, while not particularly harmonized, suffer the problem of being no stronger than the weakest link; in the event damage is caused, the trade secret is practically given a protection equal to the weakest one amongst the countries where damage has been sustained. Once public, it will have lost its essential qualities.

3.1.1 — Damage and indirect consequences

Lex loci damni poses the question, the Vorfrage: How do we determine what a damage is, in order for the main rule to apply? Recital 16 mentions direct damage, and Article 2(1) states that ”damage shall cover any consequence arising out of tort/delict, unjust enrichment, negotiorum gestio or culpa in contrahendo.” Article 4(1) excludes indirect consequences as being the base for applicable law, but what about a direct consequence, yet not a direct damage? On the one hand Article 15(c) and, by analogy from the Brussels rules, Shevill could be used to argue that national substantive law should decide, while, on the other hand, it would certainly not be the only concept with an autonomous meaning.

The exclusion of the country in which indirect consequences, such as loss of income, occurred, is consistent with ECJ rulings under the Brussels regime.

The ECJ in Dumez stated that the place where the damage occurred ”can be understood only as indicating the place where the event giving rise to the damage, and causing tortious … liability, directly produced its harmful effects upon the person who is the victim of that event.” In Marinari the place where the harmful event occurred (the ‘meta-concept’) was held not to include the place where ”the victim claims to have suffered financial damage following upon initial damage arising and suffered by him in another Contracting State.”

The Commission explained, in the Explanatory Memorandum, that ”[t]he place or places where indirect damage, if any, was sustained are not relevant for determining the applicable law. In the event of a traffic accident, for example, the place of the direct damage is the place where the collision occurs, irrespective of financial or non-material damage sustained in another country.”

Recital 17 states that, in cases of personal injury or damage to property, the country of damage should be that where the injury was sustained or the property was damaged. The delimitation between damage and indirect consequences becomes difficult in cases both of physical injury and of economic loss. What about gradual deteriorations in the victim’s condition after his return to his home country? Costs of care and loss of future earnings could well, in practice, be direct consequences of an event, if not even the actual damage. Thus, when localizing the damage, the court, according to some (Carruthers and Crawford, p. 248), ought to be entitled to take account of direct consequences of the event.

In the British case Protea, the difficult issue of assessing economic loss as damage was illustrated: ”The present action provides a good example of a case in which the country in which the economic consequences of the alleged tort were felt was not the country in which the most significant element of the events constituting that tort occurred. The damage alleged … consists mainly of failing to pay sums due under the leases but also partly in a failure to maintain the aircraft as required by the leases. The latter occurred in Cambodia and in the case of the former the location of the bank account to which payment should have been made is entirely unconnected with the conduct on which Protea relies as the basis for its claim … Cambodia … is clearly the country in which the most significant elements of the events said to constitute the tort occurred.”

3.1.2 — Causation

The damage must have been caused by the event giving rise to damage. Courts should not, however, interpret this too strictly, e.g. by applying a ‘but-for’ test. Prima facie, every ‘event giving rise to damage’ should be considered as causing some damage. (Dickinson 2, p. 311) This means that even scientifically unproven effects must be accepted as damage caused by some event, with some rather peculiar arguments following.

3.1.3 — Localization of the damage

The main rule presumes that damage can be localized to a geographical area with a legal system. There is an evidential problem involved when damage has occurred on board a mode of transportation. Naturally, localization of a damage aboard an aircraft or seacraft is more difficult than on a train or other ground transportation. Another issue is that the passengers of e.g. an aircraft are isolated from the countries over which they pass. (Dickinson 2, p. 319)

Further, the Regulation does not explicitly touch upon situations where damage has been sustained on the open sea, in space, on Antarctica, or on the Internet etc. Some suggest the use of legal fictions or other emergency solutions, while others suggest that, in the event Article 4(1) is not applicable, Article 4(3) is. (Bogdan, p. 935) This latter solution efficiently bypasses the evidential difficulties facing the court in an individual case. Article 4(3) presents, in cases of international transportation, a number of alternative countries suitable for application of the manifestly closer connection criterion, such as the country of departure, the destination, the country where the vessel is registered, and the country of the vessel operator’s habitual residence (Dickinson 2, p. 320). This solution is all the more suitable in cases of international transportation of goods, as goods themselves are unable to notify exactly when during transportation they have been damaged. (In the Brussels case Réunion Européenne v Spliethoff’s, C-51/97, the ECJ said that the ”place where the damage arose in the case of an international transport operation of the kind at issue in the main proceedings can only be the place where the actual maritime carrier was to deliver the goods”, para 33)

Concerning transportation on or over the high seas, a workable solution would be to apply the law of the flag or registration State of the damaged ship/aircraft. The only other viable solution would be to, as stated above, disregard Article 4(1) in favor of Article 4(3) (possibly Article 4(2) as well). (Dickinson 2, p. 324)

When a claimant sustains damage in several countries due to a single event, applicable law is determined by separating the damage into parts corresponding to nationality, so that country X’s law will apply to damage sustained in country X, while country Y’s law will apply to damage sustained in country Y.

3.2 — Paragraph 2

If the person claimed to be liable and the person sustaining damage (For an elaboration on these two persons as concepts, see Dickinson 2, pp. 337-339) both have their habitual residence in the same country at the time when the damage occurs, paragraph 2 says that the law of that country shall apply. The inclusion of this paragraph is to acknowledge the strong arguments for applying the law of country X to a dispute where two friends living in country X drive to country Y in a car owned by one of them, and suffer an accident in country Y, whereby the passenger is injured (disregarding Article 17 momentarily).

This is an exception to paragraph 1, and not an internal matter, because the places where the event giving rise to damage occurred, or where the damage occurred, need not be the place of the parties’ domicile. It is, seemingly, mandatory, while you could still use the escape clause in paragraph 3. The mandatory nature would appear inflexible when there are related claims against parties not habitually resident in that very country, creating a system of lex loci damni except for defendants habitually resident in the claimant’s country.

This could be criticized on the basis that States still have an interest in enforcing their conduct-regulating rules even if both parties are domiciled in the same foreign State. The paragraph is better suited to regulate national rules with the purpose of compensating the victim. (Symeonides, p. 195)

3.2.1 — Habitual residence

Habitual residence is defined in Article 23 as the place of central administration, or the principal place of business, when concerning business activities and legal persons. Habitual residence of natural persons not conducting business activities is not regulated here. In order for paragraph 2 to apply, you must, in cases of persons moving from one country to another, answer the questions of when and how a change in habitual residence came about.

The concept of habitual residence was stated in the 2003 Explanatory Memorandum to be more flexible than domicile, but it is unclear whether it is to be interpreted autonomously or referred to national law. (Wadlow, p. 317, is of the opinion that the Commission saw the concept as sufficiently simple and self-evident not to require further explanation.) Criticism of paragraph 2, that it only applies when the parties are domiciled in the same country, but not when they are domiciled in different countries with the same laws, still stands. (Symeonides, p. 196)

3.2.2 — At the time the damage occurs

The persons must be habitually resident in the same country at the time the damage occurs. This creates questions on whether the condition of habitual residence in the same country is fulfilled if only at the start of the damage, at the end of the damage, or if they must be habitually resident in the same country for the entire duration of the damage. Dickinson suggests that, for sustained damage over a period of time, the earliest point in time should be used. (Dickinson 2, p. 340)

3.3 — Paragraph 3

This escape clause provides that, where it is clear from all the circumstances of the case that the tort/delict is manifestly more closely connected with a country other than the ones in paragraphs 1 and 2, the law of that country shall apply. This could serve to eliminate the fragmentation of applicable laws inherent in Article 4(1). The paragraph is phrased in exclusively geographical terms, creating a connection to a country and not to the law of a country, and is intended to remain of exceptional use only.

Important to note is that there shall be a manifestly closer connection between a particular country and the tort/delict, and not between a particular country and the damage in itself, striking a contrast to Article 4(1). This means that factors which link a person or a situation to a specific country are not relevant, if they do not link the tort as such to that country. This is desirable in cases of multiple defendants of one and the same tortious act, where otherwise individual connections would point to different countries. Also worth noting is that it is not enough for a particular issue to be more closely connected – the tort/delict as a whole must be more closely connected. (Hartley, p. 902) Conversely, the obligation behind the tort/delict is not to be taken into account either, which means that a court is not allowed to look separately to the possibly more than one obligations that may arise from the same set of facts, e.g. when the case involves multiple tortfeasors.

Article 4(3) does not specify whether there is a temporal relevance to the connection between the tort/delict and a country; it should be applied at the time that the law applicable to the non-contractual obligation is determined. (Dickinson 2, p. 343)

The second sentence of the paragraph gives an example of what a manifestly closer connection might be – a pre-existing relationship between the parties, such as a contract, that is closely connected with the tort/delict. An employment contract could serve as a basis for determining applicable law on situations where an employee has stolen from the employer. The main advantages of applying the same law to both the tortious and the contractual aspects of a particular dispute are practical and simplistic in nature. According to the Commission, a pre-existing relationship applies in particular to pre-contractual relationships and to void contracts.

3.3.1 — Manifestly more closely connected

By its very nature, an obligation can only exist by virtue of law, and must thus be tied to a particular legal system. This argument means that a manifestly closer connection to another country becomes hard to find, as a non-contractual damage facilitates breach of an obligation under that very legal system.

As the paragraph uses exclusively geographical terms, and because an issue-by-issue evaluation is prohibited, there is a risk that courts will simply start to count physical contacts. (Symeonides, p. 204) Recital 14 provides hope in that courts seized are enabled by the Regulation to ”treat individual cases in an appropriate manner.”

Another type of criticism, already touched upon in 3.3, is that the paragraph works on an all-or-nothing approach, i.e. that the only condition for application is whether the court finds that the tort/delict has a manifestly closer connection with another country or not. One could argue that this is very inflexible. (Symeonides, pp. 204-205) It is possible that the drafters wanted to avoid dépeçage, although the immediate reply would be to ask why dépeçage is not expressly denied in Rome II at large.

What is meant by manifestly in the paragraph is unclear. Perhaps does it suggest that the criterion to be used by courts is one in which focus should be on objective factors rather than on the subjective intentions or expectations of the parties. (Dickinson 2, p. 341)

The Regulation does not elaborate further on the question on whether the law to be applied should be the one which governs a pre-existing relationship, or the one of the country in which the pre-existing relationship is primarily centered. The Explanatory Report to the 2003 Commission Proposal states that the drafters meant the first one, but this is not expressly stated in the Regulation. Applying the second possibility could, therefore, be viable.

4 — Conclusion

Some see the Rome II Regulation as a missed opportunity (Symeonides, countered by Dickinson saying that ”what’s done is done”), failing to address numerous issues in its Article 4. Habitual residence is left undefined regarding natural persons; the concept of manifestly more closely connected appears to be insufficiently flexible; the concept of damage is not defined appropriately; few of the concepts have been given an autonomous meaning, leaving most of them in the ambivalent situation where the autonomy is neither confirmed nor denied. The flaws are many and they are easy to spot – how they should be resolved is not as easy.

While lex loci damni manifests itself satisfactorily in this Regulation, there are still some problematic situations which are left inadequately resolved, such as where the causer of the event giving rise to the damage is unaware of damage caused in other Member States. As suggested by Koziol and Thiede, an exception to the main rule of lex loci damni, would lead to the Regulation not having the same negative impact on foreseeability. The instrument acknowledges the principles of Bier, Dumez and Marinari, broadening their application into the choice-of-law field and increasing their legitimacy.

The Rome II Regulation is an instrument long overdue, some 40 years after the first effort, the Benelux Uniform Law on Private International Law (1969), yet the arrival of it is, despite its shortcomings, very welcome.

Issues will be solved first and foremost by reference to the travaux préparatoires of the Regulation, secondly by analogy to the much similar rules contained in the Rome Convention and the Brussels Convention and their respective successors. It is observed that measures to codify certain concepts, such as habitual residence for natural persons, are largely absent, and one can but wonder why the institutions of the EU did not take this initiative more than they did.

Article 4(1) poses problems concerning the boundary between damage and indirect consequences. The Commission’s statement concerning that the law of the place where a traffic accident occurs shall be used, and no consideration is to be made to laws of countries where indirect damages are suffered, is not as clear-cut in other circumstances. Another problem concerns the localization of the damage. While situations where a persons sustains damage in multiple countries due to one event may be solved without much effort, the same can not be said where the damage cannot be localized to a territory, containing a legal system, at all. For such situations, we are left with applying, on a case-by-case basis, ad hoc solutions such as the public international law concept of the law of the flag (concerning international shipping) or applying Article 4(3) instead.

Paragraph 2 is an exception to the main rule of a mandatory nature. While there are good reasons for using the forum domicilii of the parties, there would still be differences in the law applied where related parties to the event/damage are present. Habitual residence for natural persons is still undefined.

Article 4(3) will probably see little practical use, due to its very exclusive nature. The concept of manifestly more closely connected will, however, just as in other instruments where it has been used, be intensely debated. Allowing dépeçage under 4(3) would better facilitate its application in a number of situations, yet doing so would perhaps be equivalent to opening Pandora’s box—not that us lawyers would complain, really!


Bogdan, Michael, ”Den nya Rom II-förordningen om tillämplig lag för utomobligatoriska förpliktelser”, SvJT 2007 s 929

Carruthers, Janeen M and Crawford, Elizabeth B, ”Variations on a Theme of Rome II. Reflections on Proposed Choice of Law Rules for Non-Contractual Obligations: Part II”, EdinLR Vol 9 pp 238-266

Dickinson, Andrew, ”Cross-Border Torts in EC Courts – A Response to the Proposed ”Rome II” Regulation”, [2002] EBLR pp 369-388 (Dickinson I)

Dickinson, Andrew, ”The Rome II Regulation: The Law Applicable to Non-Contractual Obligations”, 2008, Oxford University Press (Dickinson 2)

Hartley, Trevor C, ”Choice of Law for Non-Contractual Liability: Selected Problems under the Rome II Regulation”, ICLQ vol 57, October 2008, pp 899-908

Koziol, Helmut and Thiede, Thomas, ”Kritische Bemerkungen zum derzeitigen Stand des Entwurfs einer Rom II-Verordnung”, ZVglRWiss 106 (2007), 235 et seq.

Symeonides, Symeon C, ”Rome II and Tort Conflicts: A Missed Opportunity”, American Journal of Comparative Law Vol 56 (2008),  pp 173-222

Wadlow, Christopher, ”Trade Secrets and the Rome II Regulation on the Law Applicable to Non-Contractual Obligations”, E.I.P.R. 2008, 30(8), 309-319

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