How an American court looks at French law

The case deals with how American and French law interact to determine whether a contract can be orally modified or not, against a specific clause that prohibited oral modifications. The legal reasoning involves touches on French civil and commercial law, as well as their counterpart notions in American law.

This is a case of conflict of laws which is finally decided by the joint application of American and of French law....

Par Henry Saint Dahl

Attorney admitted in Texas, New York, Washington, D.C., Madrid and Buenos Aries.

(Lire la suite en téléchargeant la contribution ci-dessous)