kaal:claim:2029983-036
U.S. courts have only a limited capacity to integrate parties' choice of law into a post-Morrison regime for defining transaction location, and adding variables raises the risk of inconsistent case law across districts and circuits.
Source quote, verbatim
The complexities in the above discussion suggest, however, that U.S. courts have a limited capacity to integrate choice of law into a post-Morrison regime defining transaction location.
From
Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012), III.C. Integrating Choice of Law into Post-Morrison Securities Law, p. 68
https://ssrn.com/abstract=2029983 · source PDF
Cite as
Wulf A. Kaal, Richard W. Painter, Forum Competition and Choice of Law Competition in Securities Law after Morrison v. National Austral (2012). SSRN: https://ssrn.com/abstract=2029983
Holds when
Classification
failuresupport: arguedfailure: limited-judicial-capacityfamily: supervisory-capacity-gaplaw-and-legal-systems
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