October 2022— An article authored by Chaffetz Lindsey’s Andreas Frischknecht, Alex Lupsaiu and former visiting law clerk Greta Körner has just been published in the second issue of the 2022 ICC Dispute Resolution Bulletin. The article, titled ”Who Decides? Judicial Review of Arbitral Jurisdiction in the U.S. and Germany — particularly under Article V(1)(c) of the New York Convention,” examines how courts in the United States and Germany differ fundamentally in their approach to arbitral jurisdiction and the degree to which it is subject to judicial review.
But, nonetheless, the authors find that the practical outcomes in both jurisdictions are more similar than the stark differences in theory might suggest.
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