engleski

Civil Jurisdiction of European Courts over U.S. defendants

The Commission, the Council and European Parliament are currently in the midst of negotiations over a new proposal for the Brussels I Regulation on jurisdiction and recognition and enforcement of judgments in civil and commercial matters. One of the key elements of the Commission's proposal is to extend the jurisdictional rules of the regulation to third party defendants such as those in the US. Jurisdiction of courts in civil cases brought against U.S. defendants would no longer be determined by national law of each Member State but by the Brussels I Regulation. For U.S. businesses and individuals who are subject to risk of being sued in any EU member state, this raises the issue whether they would be better off or worse off if this proposal is adopted. In my talk I would like to make some introductory remarks on the regulation and discuss how it compares to U.S. jurisdictional law, as I understand it. I will then outline the Commission proposal and share with you some thoughts on what effects this may have for U.S. parties.

private international law; civil jurisdiction; EU law; Brussels I Regulation

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