That is one issue. I am afraid that this study will, in the near future, need enlargement and completion because, if we want to start an industrial property dispute arbitration system, we have first to learn which issues are arbitrable and which issues are not. On that issue the documentation is still not yet complete. But there is not only the question of arbitrability. All patents, the same applies for trademarks, of course, and designs and models, are granted under a national law with territorial effect.
Some countries even restrict the choice of law.
It is difficult to imagine that a court of arbitration deals with the question of nullity of a Swiss patent in arbitration by applying another law than Swiss law. If in the same arbitration ten different patents granted in ten different countries are at issue, you have either to find a way to apply one law to all patents, which would seem natural, or else you have the problem that the arbitration panel would have to apply ten different laws. That is also a problem not entirely resolved that merits further study. International arbitration on strict industrial property issues may have a number of question marks on the substantive laws that go with it. It is probably a bit easier when you have a contractual situation.