1.  The Community authorities follow the attribution of jurisdiction in Article 81 of the TFEU (formerly Article 65 TA): Rome I, Rome II and Rome III Regulations Rome II Regulation Rome I Regulation Rome III Regulation Unification of rules of conflict The same legal system will apply regardless of the Court of the Member State before which the claim is filed = predictability 1/4

2. Rome I, Rome II and Rome III Regulations General solutions 2/4 Rome I A)  Freedom of choice  Solutions for types of contracts  Legal system of the state where party required to effect the characteristic performance has its habitual residence  Escape clause Special solutions B)  Carriage  Consumers  Employment  Insurance

3. Rome I, Rome II and Rome III Regulations General solutions 3/4 Rome II A)  Freedom of choice (with exceptions)  Law of common habitual residence  Closer connections  Locus danmi Special solutionsB)  Product liability  Unfair competition / Acts restricting free competition  Environmental harm  Intellectual property  Collective action * Exclusion of damage to privacy, honour, etc. from the material scope of liability

4. Rome I, Rome II and Rome III Regulations Solutions 4/4 Rome III A)  Freedom of choice  In the absence of a choice, the legal systems referred to in Article 8 will be applied.  Negotiation by enhanced cooperation  Exclusion of annulment from the material scope