Marianne Micha
Der Direktanspruch im europäischen Internationalen Privatrecht
Das kollisionsrechtliche System des Art. 18 Rom II-VO vor dem Hintergrund des materiellen Rechts der Mitgliedsstaaten
[The Direct Action in European Private International Law. The Conflict of Laws System in Art. 18 of the Rome II Regulation against the Backdrop of the Substantive Law of the Member States.]
2010. 278 pages. Price for libraries
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The question of which law is applicable when an injured party takes action against the liability insurance of his (foreign) tortfeaser arises in connection with motor vehicle liability insurance and with other compulsory and voluntary liability insurances as well. Based on comparative law, Marianne Micha develops a conflict of laws system for Art. 18 of the Rome II Regulation that provides differentiated solutions for the various types of liability insurance.