Every matter is different, and professional secrecy allows us to say no more than the essentials. The situations below are anonymised; they show when the firm steps in, on which questions, and what its work changes for the client.
I. Maritime
International sale of a yacht: securing a deal across several jurisdictions
- The situation
- A foreign, English-speaking client contacted us through the website about the sale of a yacht. The deal involved several parties based in different countries and was governed by more than one legal system.
- What we did
- We reviewed the transaction documents, identified the questions of French and international law it raised, and advised the client on the precautions needed to secure the transaction. All exchanges took place in English.
- What the client gained
- The client went ahead with the deal knowing its legal risks and the guarantees to obtain before signing.
Further reading: buying and selling a yacht or ship, pre-purchase due diligence
II. Export and import
International sale of goods: establishing each party’s rights
- The situation
- A company ran into difficulty in performing an international sale of goods and wanted to know what it could demand, and how.
- What we did
- We analysed the contract, the rules specific to international sales and the private international law factors likely to weigh on the dispute: governing law, competent court, and whether a decision could be enforced where the other party was based.
- What the client gained
- The client settled on a legal and commercial strategy before taking any step towards litigation, knowing what it could obtain and at what cost.
Further reading: the contract that really binds you, international contracts, Incoterms and international sales
III. Enforcing a decision
Giving effect in France to a decision handed down in the United States
- The situation
- A foreign client needed the effects of a legal situation established by a US decision to be recognised in France, where substantial assets were held by French institutions.
- What we did
- We analysed the conditions for recognising and enforcing the foreign decision in France, then prepared the necessary steps with the French institutions and courts concerned.
- What the client gained
- The client was able to secure, on a sound legal footing, access to and management of its assets in France.
Further reading: enforcing a decision internationally, exequatur, enforcing a foreign judgment in France
IV. International dispute
Foreign proceedings, assets in France
- The situation
- A client faced proceedings brought abroad in an international dispute over significant assets, part of which were located in France.
- What we did
- We studied how the foreign proceedings interacted with French law, identified the risks that could reach the assets in France and set out a strategy to defend and protect those interests.
- What the client gained
- The French risk was built into the overall strategy of the case, instead of being discovered at the end of the proceedings.
Further reading: international commercial litigation, enforcing a decision internationally
IV. International dispute
A French company sued in the United States by a US customer
- The situation
- A French company was sued before a US court by one of its American customers. It had to defend itself in the United States while protecting its position in France, where its assets are.
- What we did
- Applying the rules of private international law, we examined the jurisdiction of the US court, the law governing the contractual relationship and the conditions on which a US judgment could be recognised and enforced in France. That analysis shaped a consistent defence on both sides of the Atlantic.
- What the client gained
- The company conducted its US defence knowing what a judgment could and could not achieve in France, and prepared its French position accordingly.
Further reading: international commercial litigation, exequatur, international arbitration
These summaries are anonymised and simplified. They do not predict the outcome of other matters, since each case turns on its own facts and on the law that applies to it.
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