Gesamtverweisung

Substantiv

neolog

comprehensive foreign law reference

Comparative law notes

comprehensive reference not just to foreign substantive law, but also to that foreign jurisdiction's own conflicts of law rules (i.e., reference to the foreign law including that laws of conflicts of law rules). Such a comprehensive reference can trigger a kind of ping-pong match in which the foreign conflicts rules may require that the forum's court substantive laws be ultimately applied to the case.