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Buyer and seller are citizens of the United States and France respectively. Both countries have adopted the CISG. However as the performance of the contract 9s going to take place in th US, they decide that the US would have jurisdiction to hear disputes and the applicable law shall be that of the US. When a dispute arises, Seller claims that given the different legal traditions followed the applicable law should be the CISG. Buyer argues that the law of the US has been specifically mentioned in the contract and hence the CISG cannot be applied to in the settlement of disputes. Whom do you think is correct? Discuss.

Operation Management, Management Studies

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