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In what order are choices made
about governing law, seat and
institution/rules and do the
choices influence one another?
However, a number of interviewees also said
that depending on the relative bargaining
positions of the parties, their location, their
legal cultures and the nature of the contract,
the apparent ‘nexus’ between governing law
and seat and, to a lesser extent, institution
may be broken and the various parts of the
clause traded off as part of negotiations.
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