Jurisdiction agreements and comparative interpretations between England and us courts. The role of private internacional law of European Union

Abstract

The present survey aims to focus on the delimitation of some definitive findings. The simple choice of terminology is charged with consequences on the conceptual level: "agreements on the forum", "clauses derogating from jurisdiction" or "agreements on the extension of jurisdiction" ? While when we talk about agreements on jurisdiction we have in mind especially the phenomenon in its civil and commercial declension, in the sense in which these expressions are traditionally used in international instruments as we see in a comparative manner with our research.