The Hague Convention on Choice of Courts Agreements (“Convention” or “Choice of Court Convention”) aspires to be one of the most significant private international law treaties of this century. The Convention would substantially alter existing rules in many jurisdictions, including the United States, governing the recognition and enforcement of both international choice-of-court agreements and judgments obtained in proceedings based on such agreements. The Convention’s drafters and other proponents promote it as replicating both the terms and success of the New York Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”), transposed to cross-border forum selection agreements.
Volume 169Issue 8 2021 Article