bluuebunny/crossref_metadata_2025_split huggingface dataset:
Bahrain
Authors: Elbalti Béligh , Shaaban Hosam Osama 
Published: May 2021

Abstract
This chapter assesses Bahraini perspectives on the Hague Principles. In Bahrain, private international law rules are mainly found in domestic legislation. The main legislative text in this regard is the Act No 6/2015 on Conflict of Law in Civil and Commercial Matters involving a Foreign Element (the 2015 Act). The Act includes a number of rules of general application, among which is Article 4 on party autonomy in addition to some other rules relating to choice of law in contractual matters in general (Article 17) or applicable to special types of contracts and other juristic acts. It can be safely said that nothing in principle prevents the Bahraini courts from referring to the Hague Principles as a persuasive authority nor from using its solutions in the interpretation or the development of the applicable rules and principles of private international law in Bahrain. This is particularly true knowing that many of the solutions adopted by the 2015 Act are particularly consistent with the Hague Principles’ solutions.
China (Mainland)
Authors: He Qisheng 
Published: May 2021

Abstract
This chapter addresses Chinese perspectives on the Hague Principles. The modern legislation of private international law in China began with the establishment of choice of law in contracts. The first statute enacting private international law rules was the Foreign Economic Contract Law of 1985. Article 5 of the Law stipulated that the parties to a contract may choose the law applicable to the contract dispute. Since the promulgation of the Foreign Economic Contract Law, party autonomy and the closest connection doctrine have been two major approaches in determining the law applicable to a contract dispute. In 2010, the National People’s Congress of China promulgated a new private international law: the Law of the People’s Republic of China (PRC) on Application of Law for Foreign-Related Civil Relationships. The chapter then compares the current position of private international law of contract in Mainland China with the Hague Principles.
Dubai International Financial Centre
Authors: Elrifai Silke Noa 
Published: May 2021

Abstract
This chapter describes the Dubai International Financial Centre (DIFC) perspectives on the Hague Principles. Whereas the DIFC is bound by international treaties ratified by the United Arab Emirates (UAE) on a federal level, the DIFC’s domestic sources of private international law are laid down in several statutory enactments and, as a common law jurisdiction, also case law. The most important rules on choice of law in international contracts are codified in the DIFC Law No 10 of 2005 (the DIFC Law Application Law), which govern the law applicable to contractual obligations. It sets out clearly and succinctly the most important applicable law rules, which respect the parties’ autonomy to choose the applicable law. Although Article 30(1) of the DIFC Court Law clearly instructs the DIFC Courts what law they must apply, Article 30(2) authorizes the DIFC Courts to ‘consider decisions made in other jurisdictions for the purpose of making its decision’. Accordingly, so far as the Hague Principles have been referenced in decisions in other jurisdictions, the Court may also refer to them.
Indonesia
Authors: Lumbantobing John , Hardjowahono Bayu Seto 
Published: May 2021

Abstract
This chapter highlights Indonesian perspectives on the Hague Principles. Generally speaking, private international law (PIL) in Indonesia is not an area of law where statutory rules have developed in a comprehensive and systematic manner. Rules on many aspects of private international law, including the freedom of choice of law, remain very rudimentary and do not address sufficiently complicated legal questions surrounding modern commercial transactions. The chapter then analyses Indonesian PIL doctrines and court decisions on party autonomy in contracts. It is uncertain whether and how far the Hague Principles can be accepted as a persuasive authority in the interpretation, supplementation, and/or development of the applicable rules and principles of private international law before the Indonesian courts. In principle, there is no restriction for the courts to refer to international instruments as sources of inspiration for interpreting or filling gaps of existing rules. However, Indonesian courts are infamously insular and are not receptive to foreign materials, particularly ‘soft law’ resources which are not part of national laws of a sovereign state.
Iran
Authors: Yassari Nadjma 
Published: May 2021

Abstract
This chapter presents Iranian perspectives on the Hague Principles. Generally, private international law is not very developed in Iran, neither in theory nor in practice. This is for diverse reasons: the history and the legacy of the capitulations systems, according to which foreign citizen and entities were exempted from Iranian jurisdiction, is still vividly felt, as is the fear of potential foreign domination. This has nurtured a general suspicion towards the application of foreign law as a gateway for political intervention of foreign powers. Following the revolution of 1979, the political situation and the instability and insecurity of foreign investments have been major impediments to the spread of international commerce between Iran and the rest of the world, diminishing the need to establish efficient private international law tools. This factual situation is mirrored by a poor engagement with international contract law in scholarly writings, which often remain hypothetical and abstract due to the lack of case law. Nowhere in the literature is any reference made to the Hague Principles. Only in the field of international arbitration has there been some movement: in 1997, the Law on International Commercial Arbitration (LICA) was enacted, a code that relies greatly on the United Nations Commission on International Trade Law (UNCITRAL) Model Law.
Vietnam
Authors: Doan Duc Luong , Nguyen Thi Hong Trinh 
Published: May 2021

Abstract
This chapter reflects on Vietnamese perspectives on the Hague Principles. In Vietnam, the sources of private international law in respect of international commercial contracts includes the bilateral judicial assistance treaties between Vietnam and related countries, among which eight treaties contain conflict rules for the content of the contract and eleven treaties contain conflict rules for the parties’ capacity in entering the contract. As for national legislation, which is established in Vietnam as the major source of private international law, the Vietnamese Civil Procedure Code (VCPC) 2015 provides for the procedures regarding civil disputes with foreign elements (Part VIII) and the recognition and enforcement of the decisions of foreign courts and the decisions of foreign arbitrators in Vietnam (Part VII). At the same time, the Vietnamese Civil Code (VCC) 2015 contains Part V which regulates the law applicable to civil relations involving foreign elements. As far as the Hague Principles are concerned, this is being addressed in the drafting stage of Part V of the VCC 2015 (on conflict rules). The influence of the Hague Principles on the Vietnamese legislature may be stronger when they are more well known in the future.
Russia
Authors: Karayanidi Milana 
Published: May 2021

Abstract
This chapter addresses Russian perspectives on the Hague Principles. It analyses choice of law rules applicable to international commercial contracts in Russia. These rules apply to contracts that have a foreign element from a Russian standpoint and they are codified in a variety of sources, including the Civil Code, the Code of Civil Procedure, the Code of Arbitrazh Procedure, the Federal Law on Fundamentals of State Regulation of International Trade, and numerous other statutes on specific issues. International treaties to which Russia is a signatory State also regulate private international law issues, and the provisions of such treaties prevail over Russian domestic law in case of a conflict. Generally, courts in Russia are also not forbidden to refer to other international instruments when such sources are directly incorporated into an agreement between private parties. Russian courts will also enforce terms of customary business practices, where parties to international commercial contract agree to use them. Although there is no ongoing reform relating to the law applicable to cross-border contracts in Russia, the comparison of Russian private international law rules and the Hague Principles shows that the Hague Principles may play a role in improving relevant rules in Russia.
Ukraine
Authors: Vorobey Dmytro 
Published: May 2021

Abstract
This chapter studies Ukrainian perspectives on the Hague Principles. Ukrainian private international law act, or formally the ‘Law of Ukraine “On Private International Law” ’ (PIL), was adopted on June 23, 2005. As per the Preamble to the PIL, it applies to ‘private [legal] relationships which are connected to one or more legal orders other than the Ukrainian legal order’. According to Article 2 of the PIL, it applies to matters of choice of law, procedural standing of foreign citizens, stateless persons and foreign legal entities, jurisdiction of Ukrainian courts in cases involving foreign parties, execution of letters rogatory, and recognition and enforcement of foreign court judgements in Ukraine. The Ukrainian private international law and specifically the PIL were influenced by the 1980 Rome Convention on the Law Applicable to Contractual Obligations. Although, considering the relative novelty of the Hague Principles, the authority of the courts to refer to the Hague Principles has not been addressed by the higher Ukrainian courts, the courts have frequently referred to the international codifications of contract law such as the UNIDROIT Principles of International Commercial Contracts.
United Kingdom
Authors: Dickinson Andrew 
Published: May 2021

Abstract
This chapter highlights United Kingdom perspectives on the Hague Principles. On 31 January 2020, the UK ceased to be a member of the EU. Under the terms of the Withdrawal Agreement concluded between the UK and the EU, the UK will apply the Rome I Regulation to contracts concluded before the end of the transition period. The UK has taken a policy decision to continue to apply the Rome I Regulation to determine the law applicable to contractual obligations with respect to contracts concluded after the end of the transition period, and has adopted legislation to achieve that end. Following the ‘IP completion day’, UK courts will have no power to refer questions of law to the EU’s Court of Justice (CJEU) and will not be bound by decisions of the CJEU made after that date, although they ‘may have regard to’ such decisions. In the absence of a significant existing body of CJEU case law concerning the Rome I Regulation and its predecessor, the 1980 Rome Convention on the law applicable to contractual obligations, UK courts will seek guidance from the existing body of local case law, which will continue to bind them in accordance with common law rules of precedent. In this enterprise, the Hague Principles, as an instrument adopted by the members of a well-respected international legal organization of which the UK is a long-standing member, may prove to be an influential tool, especially when addressing novel questions.
Argentina
Authors: All Paula María 
Published: May 2021

Abstract
This chapter discusses Argentine perspectives on the Hague Principles. As regards conventional private international Law, Argentina has ratified the Montevideo Treaties on International Civil Law of 1889 and 1940, which regulate the law applicable to international contracts in Articles 32–39 and 36–42, respectively. Concerning domestic private international Law, its provisions are envisaged in the Argentine Civil and Commercial Code and special statutes. On 7 October 2014, Argentina enacted a new Civil and Commercial Code (CCyCN, for its Spanish acronym), which came into force on 1 August 2015. The regulatory sources consulted for the drafting of the New Code did not include the Hague Principles. Nevertheless, were the CCyCN to be amended in the future, nothing would prevent the Hague Principles from being considered at the time of modifying rules on the law applicable to international contracts. Within the judicial framework, Argentine courts may use the Hague Principles in order to interpret or supplement rules of law on the law applicable to international contracts.
Bolivia
Authors: Schütt José Manuel Canelas 
Published: May 2021

Abstract
This chapter examines Bolivian perspectives on the Hague Principles. Bolivia has few legal provisions and little meaningful legal precedent referring to international commercial contracts and choice of law. Nevertheless, Bolivia’s legal system recognizes the importance of party autonomy, custom, usage, equity, and even culture in contract law. In that sense, the Hague Principles may be useful in a variety of ways, such as supplementing or re-interpreting national laws, as guidance for legal reform, or as incorporated by reference into a contract. The existing legal vacuums in Bolivian law may at times offer even broader opportunities for their use than in other jurisdictions where the law is more developed. The Hague Principles could be applied by courts and arbitral tribunals as a subsidiary source of law, either in cases where there is no specific rule applicable to the matter at hand or in cases where the Hague Principles would be helpful to interpret the applicable conflict rule. The application of the Hague Principles cannot contradict Bolivia’s mandatory rules or public policy. For an effective use of the Hague Principles, it should be noted how these are in line with constitutional principles, particularly party autonomy.
Chile
Authors: Gallegos-Zúñiga Jaime 
Published: May 2021

Abstract
This chapter focuses on Chilean perspectives on the Hague Principles. Due to the scarce and mostly unilateral provisions on private international law contained in Chilean legislation, there remain large gaps in the system. Chilean judges must therefore deduce relevant principles, and the result is often unclear solutions. Nevertheless, the recognition of party autonomy is increasingly gaining ground in academic literature and court judgments. On 2 October 2017, the Ministry of Justice and Human Rights, the Faculty of Law at the University of Chile, and the Chilean Association of Private International Law signed an agreement to compose a Draft Act of Private International Law. This work is being developed by a commission of specialists and originally revolved around the draft Model Act of the Organization for the Harmonization of Business Law in the Caribbean (OHADAC) of 2014. Many of the ideas contained in the Hague Principles have been acknowledged and included in the draft, which is expected to be submitted to the National Congress. Given the lack of rules that specify the scope of party autonomy, the provisions contained in this instrument would be a welcome contribution to the Chilean legal system.
Panama
Authors: Montenegro Carlos Alberto Arrue 
Published: May 2021

Abstract
This chapter studies Panamanian perspectives on the Hague Principles. In relation to obligations and contracts, the Panamanian Civil Code reproduces Book IV, ‘Of Obligations and Contracts’, of the Spanish Civil Code of 1889, but contains a number of important differences in other sections. In terms of sources of law, statutes occupy the most prominent position among sources of law. Consequently, neither interpretations given by Panamanian courts, nor decisions on previous cases, are binding for courts that must then decide on similar cases, even when the same provisions apply. Nevertheless, judicial decisions may, and in fact usually do, serve as an illustration on the correct application or interpretation of a legal rule. It is in this limited context that the Panamanian courts may refer to the Hague Principles and other principles of private international law and/or international contracts. The latter will not have an automatic or binding effect, but they may provide legal authority upon which the court may depend to properly interpret similar provisions of Panamanian private international law, or otherwise develop and complete legal gaps in Panamanian private international law.
Uruguay
Authors: de Aguirre Cecilia Fresnedo 
Published: May 2021

Abstract
This chapter reflects on Uruguayan perspectives on the Hague Principles. In Uruguay, international commercial contracts are regulated by the following conventions: the Montevideo Treaty on International Civil Law of 1889; the Montevideo Treaty on International Civil Law of 1940; the Additional Protocol to the Montevideo Treaty on International Civil Law of 1940; and the Buenos Aires Protocol on International Jurisdiction in Contractual Matters. They are also regulated under the domestic private international law rules contained within the Appendix of the Civil Code of Uruguay. The Appendix of the Civil Code, including rules regulating contract, is under revision; a Draft General Act on Private International Law is in Parliament under consideration. It seems unlikely that the Hague Principles will play any role regarding this Draft Act at present; however, the draft has yet to be approved mainly due to disagreement on the role of party autonomy. If the Draft Act is approved and entered into force, the Hague Principles may become useful in Uruguayan law.
United States of America
Authors: Symeonides Symeon C , Cohen Neil B 
Published: May 2021

Abstract
This chapter focuses on American perspectives on the Hague Principles. At the state level, Louisiana and Oregon have enacted comprehensive choice of law codifications, which strongly endorse party autonomy. Many other states have enacted statutory provisions that affect party autonomy. At one end of the spectrum, there are provisions that prohibit or restrict outbound choice of law clauses in certain contracts that have enumerated contacts with the enacting state. At the other end of the spectrum, there are statutes designed to ensure enforcement of inbound choice of law clauses in certain commercial contracts with high-dollar value, even in the absence of any connection with the enacting state. Despite the multiplicity of state statutes, many of which pre-empt a judicial choice of law or obviate the need for it, the bulk of American conflicts law for matters other than those governed by the Uniform Commercial Code is found in judicial decisions. In keeping with the common law tradition, American courts play an active role in the development of the law, both in general and regarding party autonomy in particular. One hopes that American courts will take into account the Hague Principles, if only for answering those questions, as few as they may be, whose answer is unclear under American law.
Respiratory Viral Pathogens Among U.S. Military Personnel at a Medical Treatment Facility in Hawaii From 2014 to 2019
Authors: Montgomery Agnes S , Lustik Michael B , Reichert-Scrivner Susan A , Woodbury Ronald L , Jones Milissa U , Horseman Timothy S 
Published: May 2021

ABSTRACT

Introduction
Acute respiratory diseases account for a substantial number of outpatient visits and hospitalizations among U.S. military personnel, significantly affecting mission readiness and military operations. We conducted a retrospective analysis of respiratory viral pathogen (RVP) samples collected from U.S. military personnel stationed in Hawaii and tested at Tripler Army Medical Center from January 2014 to May 2019 in order to describe the etiology, distribution, and seasonality of RVP exposure in a military population.

Materials and Methods
Samples were analyzed by viral culture or multiplex PCR. Distribution of respiratory viruses over time was analyzed as well as subject demographic and encounter data. Presenting signs and symptoms were evaluated with each RVP.

Results
A total of 2,576 military personnel were tested, of which 726 (28.2%) were positive for one or more RVP. Among positive tests, the three most common viral pathogens detected were influenza A (43.0%), rhinovirus (24.5%), and parainfluenza (7.6%). Symptoms were generally mild and most frequently included cough, fever, and body aches.

Conclusion
Our study evaluated respiratory virus prevalence, seasonality, and association with clinical symptoms for military personnel in an urban tropical setting in Oahu, HI, over a 5-year period. We show that viral prevalence and seasonality in Hawaii are distinct from those of the CONUS. Results contribute to the broader understanding of seasonality, clinical manifestation, and demographics of RVP among active duty military personnel stationed in Hawaii.
In vitro and in vivo interaction of caspofungin with isavuconazole against Candida auris planktonic cells and biofilms
Authors: Nagy Fruzsina , Tóth Zoltán , Nyikos Fanni , Forgács Lajos , Jakab Ágnes , Borman Andrew M , Majoros László , Kovács Renátó 
Published: May 2021

Abstract
The in vitro and in vivo efficacy of caspofungin was determined in combination with isavuconazole against Candida auris. Drug–drug interactions were assessed utilizing the fractional inhibitory concentration indices (FICIs), the Bliss independence model and an immunocompromised mouse model. Median planktonic minimum inhibitory concentrations (pMICs) of 23 C. auris isolates were between 0.5 and 2 mg/l and between 0.015 and 4 mg/l for caspofungin and isavuconazole, respectively. Median pMICs for caspofungin and isavuconazole in combination showed 2–128-fold and 2–256-fold decreases, respectively. Caspofungin and isavuconazole showed synergism in 14 out of 23 planktonic isolates (FICI range 0.03–0.5; Bliss cumulative synergy volume range 0–4.83). Median sessile MICs (sMIC) of 14 biofilm-forming isolates were between 32 and &gt;32 mg/l and between 0.5 and &gt;2 mg/l for caspofungin and isavuconazole, respectively. Median sMICs for caspofungin and isavuconazole in combination showed 0–128-fold and 0-512-fold decreases, respectively. Caspofungin and isavuconazole showed synergistic interaction in 12 out of 14 sessile isolates (FICI range 0.023–0.5; Bliss cumulative synergy volume range 0.13–234.32). In line with the in vitro findings, synergistic interactions were confirmed by in vivo experiments. The fungal kidney burden decreases were more than three log volumes in mice treated with combination of 1 mg/kg caspofungin and 20 mg/kg isavuconazole daily; this difference was statistically significant compared with control mice (P &lt; 0.001). Despite the favorable effect of isavuconazole in combination with caspofungin, further studies are needed to confirm the therapeutic advantage of this combination when treating an infection caused by C. auris.