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I imagine that if we really want authorized certainty – my objection is a technical one – if we actually need to introduce ‘buying round’ with regard to the selection of relevant law, if we really wish to abide by the weakest code of law – because let us not neglect that to decide on a law you need consensus and that consensus will also be subject to appreciable strain – if we really wish to construct a European legal space then, in my opinion, it’s a good factor for all of these amendments that the choice of law be limited to the laws of the 27 states of the European Union.

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