China 30 January 2000 CIETAC Arbitration proceeding (Ink cartridge case) [translation available]
[Cite as: http://cisgw3.law.pace.edu/cases/000130c1.html]
DATE OF DECISION:
DATABASE ASSIGNED DOCKET NUMBER: CISG/2000/10
CASE HISTORY: Unavailable
SELLER'S COUNTRY: Hong Kong (respondent)
BUYER'S COUNTRY: People's Republic of China (claimant)
GOODS INVOLVED: Ink cartridges
PRC: Award of China International Economic & Trade Arbitration Commission [CIETAC] 30 January 2000 (Ink cartridges case)
Case law on UNCITRAL texts (CLOUT) abstract no. 803
Reproduced with permission of UNCITRAL
The case concerns a dispute between a seller (respondent) from Hong Kong, and a buyer and its agent (claimants), both from China. The contract goods were ink cartridges that the claimants alleged to be defective.
The Arbitral Tribunal ruled that Chinese domestic law should apply to the contract. The tribunal made reference to the product quality law of the People's Republic of China and Article 36 CISG as an international trade usage commonly adopted. The Tribunal recognized that the goods had severe defects and could not be used as a commodity, therefore pursuant to the Chinese product quality law and the CISG, the claimant had the right to return them, and the seller was condemned to refund them accordingly. Damages were also awarded.Go to Case Table of Contents
APPLICATION OF CISG: No. Domestic law of China applied. However, the tribunal regarded Article 36 of the CISG as relevant "as an international usage adopted commonly".
APPLICABLE CISG PROVISIONS AND ISSUES
Key CISG provisions at issue:
Classification of issues using UNCITRAL classification code numbers:
36B2 [Lake of conformity occurring after passage of risk: guarantee of continued conformity]
36B2 [Lake of conformity occurring after passage of risk: guarantee of continued conformity]
CITATIONS TO OTHER ABSTRACTS OF DECISION
CITATIONS TO TEXT OF DECISION
Original language (Chinese): Unavailable
Translation (English): Text presented below
CITATIONS TO COMMENTS ON DECISION
UnavailableGo to Case Table of Contents
Case text (English translation)
Queen Mary Case Translation Programme
Ink cartridge case (30 January 2000)
Translation [*] by Meihua Xu [**]
Edited by John W. Zhu [***]
The First Claimant: China Guangdong A Company; the Second Claimant: China Guandong B Company; the Respondent: Hong Kong B Company.
The China International Economic and Trade Arbitration Commission Shenzhen Sub-Commission (hereafter, the "Shenzhen Sub-Commission") accepted the case on 25 October 1999 according to:
|-||The arbitration clause in the Sales Contract (hereafter, the "Contract") signed by First
Claimant, China Guangdong A Company, and Respondent [Seller], Hong Kong P
Company on 3 November 1998; and
|-||The written arbitration application and evidence submitted by First Claimant and Second Claimant, China Guangdong B Company (hereinafter, collectively, the "Claimants").|
Since the amount in dispute in this case is less than renminbi [RMB] 500,000, according to Article 64 of the Arbitration Rules of the Arbitration Commission (which became effective on 10 May 1998, hereafter, the "Arbitration Rules"), the summary procedure is applicable to this case.
Because the parties failed to jointly appoint or ask the Chairman of the Arbitration Commission to appoint a sole arbitrator within the stipulated time, in accordance with related provisions of the Arbitration Rules, on 13 December 1999 the Chairman of the Arbitration Commission appointed Mr. H as the sole arbitrator to form the Arbitration Tribunal to hear this case.
The Secretariat of the Shenzhen Sub-Commission sent the Claimants' arbitration application and the evidence and arbitration documents to the [Seller], and the [Seller] submitted defense and evidence thereafter.
On 30 December 1999, a court session was held in Shenzhen. The parties attended the court session. The parties and their representatives presented at the court session and had no objections to the formation of the Arbitration Tribunal. The parties made statements and presented arguments and the Arbitration Tribunal asked questions and made investigations.
On 30 January 2000, the Arbitration Tribunal handed down this award. The following are the facts, the parties' main dispute, the Tribunal's analysis, and award.
I. FACTS AND MAIN DISPUTES OF THE PARTIES
Since 23 October 1998, the parties in this case had entered into two transactions by which the Claimants were to sell the [Seller]'s P brand printer ink cartridges. A dispute arose and the Claimants filed the arbitration application with the Shenzhen Commission, seeking to have the Shenzhen Sub-Commission rule that:
|(1)||The goods shall be returned to the [Seller] due to defects on the ink-jet printer ink cartridge, and the [Seller] shall refund the price for the goods of 26055.53 Deutsche Mark [DM];
|(2)||[Seller] shall compensate the loss of the Claimants of RMB 118,244.46 and Hong Kong dollars [HK $] 1,040;
|(3)||[Seller] shall bear the arbitration fee.|
POSITION OF THE PARTIES
The Claimants allege that on 23 October 1998, the Second Claimant and the [Seller] confirmed via written document that the Second Claimant was authorized to distribute [Seller]'s P brand products in 17 provinces/cities in China, including Guangdong and Fujian Provinces. The [Seller] issued a "Distributor Certificate", appointing the Second Claimant as its agent in China (except for Jiangsu, Zhejiang, Hubei, Sichuan, Anhui, Hebei, Liaoning, Heilongjiang, and Jilin Provinces) to sell P brand products, and as a distributor in Beijing and Shanghai. The [Seller] also provided a "global guarantee for ink-jet printer ink", an "after-sales guarantee for ink-jet printer cartridges" and product advertising documents.
Since the Second Claimant had no import and export authority, on 17 October 1998, it signed an import agency agreement with the First Claimant, entrusting the First Claimant to import the aforesaid P brand products for the Second Claimant to sell in China.
On 3 November 1998, the First Claimant signed the Contract with the [Seller] (for the first delivery), by which the First Claimant purchased P brand ink and cartridges for a total price of 14,773.80 DM, FOB Hong Kong. The destination port was Gaoming. The First Claimant has made payment in accordance with the Contract, and this Contract has been fully performed.
On 4 February 1999, the Second Claimant and the [Seller] confirmed via fax that the Second Claimant was to purchase P brand ink and cartridges (for the second delivery) for a total price of 62,137.40 DM delivered to Hong Kong. The Second Claimant has paid the price in HK $62,137.40 to the [Seller] through Hong Kong X Computer System Company, and the [Seller] has delivered the goods under this contract to X Company as instructed by the Second Claimant.
During the resale of the aforesaid P brand ink and cartridges, many clients of the Second Claimant complained about defects in the goods, asking for the return of the goods and compensation for their damages. On the Claimants' application, on 9 June 1996, China Import & Export Commodity Inspection Bureau in Guangdong Province (hereafter, "CCIB Guangdong") inspected the goods (the cartridges) under this Contract and issued an inspection report indicating that "the packages of the goods are undamaged. After opening the boxes, some of the goods had ink leakage." The CCIB Guangdong therefore, concluded that "since the packages of the goods were undamaged, the ink leakage problem on part of the cartridges was caused by the goods intrinsic defects."
After receiving claims from its clients, the Second Claimant informed the [Seller] by phone calls and letters and faxed the clients' complaining letters and inspection certificate to the [Seller], asking for the return of the goods and refund of the price. However, Claimants alleged that the [Seller] did not respond timely and intentionally prolonged settling this issue, causing the dispute to be unable to be solved by negotiation.
Due to the defects on [Seller]'s P brand products, the Claimants were unable to sell the products in China. Most of the goods that have been sold or distributed by others have been returned to the Claimants, and are stored in the warehouse. The failure of the agency plan caused severe economic loss to the Claimants. Based on the quantity of the goods stored in the warehouse, the price (purchasing price) for the goods to be returned for the first delivery is 14,888.65 DM, and 11,166.88 DM for the second delivery. Therefore, the Claimants seek to have the [Seller] refund a total of 26,055.53 DM for the goods in the aforesaid two deliveries.
The defects on [Seller]'s P brand products not only caused damages to the reputation and image of Claimants' companies, but also led to the Claimants' failure to sell the ink and ink cartridge products in China, with the result that the Claimants suffered economic loss, totaling RMB 118,244.46 and HK $1,040. The following are the damages in detail:
|(1)||Transportation fee: HK $1,040;|
|(2)||Customs application fee and loading and unloading fee: RMB 131;|
|(3)||Import tax: RMB 12,618;|
|(4)||Value added tax: RMB 16,445.46;|
|(5)||L/C modification charge: RMB 850;|
|(6)||P brand products technical manual printing fee: RMB 3,900;|
|(7)||Business representatives' (four persons) training fee: RMB 4,000;|
|(8)||Business representatives' (four persons) 6-month salaries: RMB 48,000;|
|(9)||Staff traveling fee: RMB 10,000;|
|(10)||Office rental fee, phone bill and reception fee: RMB 10,000;|
|(11)||Attorneys' fee and traveling fee for this case: RMB 15,000|
The Claimants' allege that the [Seller] was obligated to provide conforming goods and be responsible for quality of the goods: therefore, the [Seller] should bear civil liability for the defects on the goods. The Claimants filed the arbitration application, asking the Arbitration Tribunal to rule that the [Seller] shall accept the return of the goods and make refund (26,055.53 DM); and that the [Seller] shall compensate the loss of the Claimants, totaling RMB 118,244.46 and HK $1,040.
The [Seller] counter argues that:
The Claimants' allegation has no basis for the following reasons:
|(1)||Based on article 12 of the Contract, "the buyer has the right to claim compensation within 90 days after the goods are unloaded at the destination port by providing an inspection certificate issued by the CCIB". The goods were delivered to the Claimants before 25 November 1998. However, it was not until 28 May 1999 that the Claimants raised quality objections, which was beyond the 90 days compensation claim period as stipulated in the Contract. Therefore, the Claimants' claims are invalid;
|(2)||The inspection certificate issued by CCIB Guangdong has no effect on compensation claims. Pursuant to article 12 of the Contract, the inspection must be conducted within 90 days after the goods were unloaded at the destination port. However, the inspection conducted by CCIB Guangdong on 9 June 1999 was beyond the 90 days limitation. Therefore, it has no effect on Claimants' compensation claim;
|(3)||The Claimants' claims which are beyond the scope of the Contract are not within the Arbitration Tribunal's jurisdiction. Also, since there was no arbitration clause in the contract for the second delivery, the Arbitration Tribunal should not accept claims for the second delivery;
|(4)||The [Seller] actively responded to the Claimants' quality objection in a timely manner, asking the Claimants to mail two samples to Hong Kong. Because the engineer of the [Seller] was in Switzerland, samples needed to be mailed to Switzerland for inspection. Even though the compensation claim period had expired, the Claimants still refused to mail samples, which indicated that they had no intention to solve the problem.|
Thus, the [Seller] asks the Shenzhen Sub-Commission to dismiss the Claimants' claims and protect the [Seller]'s legal rights.
II. THE TRIBUNAL'S ANALYSIS AND OPINION
The parties in this case have no express agreement on applicable law. Considering the fact that the places for contract formation and performance are all in China and pursuant to the proximate connection principle, Chinese domestic law shall be applied to the Contract in this case.
(1) Based on the evidence and the court session, the Arbitration Tribunal ascertained that:
1. On 17 October 1998, the First Claimant and the Second Claimant signed an import agency agreement (hereafter, the "Agency Agreement") with the following content:
|-||The Second Claimant entrusts the First Claimant to import color printing cartridges;
|-||The First Claimant is responsible for the entire import procedures including customs application, inspection, and transportation, and the Second Claimant is responsible for the entire expenses;
|-||The First Claimant charges 2% of the price for the goods as a commission, and the First Claimant shall issue a value added invoice;
|-||The First Claimant shall cooperate with the Second Claimant in making payment through a bank, which shall not exceed the amount indicated in the customs application form, and the Second Claimant shall bear the entire costs for making payment.|
2. Before the First Claimant concluded the Contract with the [Seller], the Second Claimant and the [Seller] had signed a document on 23 October 1998, confirming that in July 1998, the Second Claimant sent the first purchase order (hereafter, "First Purchase Order") to the [Seller], and that the Second Claimant was appointed as the agent of the [Seller] for the sales of P brand products in 17 provinces in China, including Guangdong and Fujian Provinces and Tianjin City, and the distributor of the [Seller] in Beijing and Shanghai. Meanwhile, the [Seller] provided a "global guarantee for ink-jet printer ink", assuring that:
|-||P brand ink would be sold only after a complete quality inspection;
|-||Research and improvement during manufacturing and long time experiences guarantee the high quality of the goods, and the goods only use materials which have been proved to be reliable;
|-||No problem has been reported under proper operation of ink-jet printers; please notify us immediately if there is any allegation that P brand product causes damage to the equipment;
|-||We would be responsible if it is confirmed that our product causes an accident.|
3. As an agent of the Second Claimant, on 3 November 1998, the First Claimant concluded the Contract with the [Seller] for the goods listed in the First Purchase Order with the following terms:
|-||Goods: The [Seller] was to sell one batch of ink cartridges (see the attachment for details);|
|-||Price: 14,773.80 DM, FOB Hong Kong;|
|-||Shipment: Departure port is in Hong Kong and the destination port is Gaoming;|
|-||Payment: by L/C;|
|-||Inspection: Buyer has the right to re-inspect the goods by CCIB Guangzhou;|
|-||Compensation claim: Except for problems for which the insurance company or the carrier shall be liable, the buyer has the right to ask compensation from the [Seller] for lack of conformity of the quality, specification, or quantity of the goods actually delivered with the provisions of the Contract, L/C, or invoice, by providing an inspection certificate issued by the CCIB.|
The Contract has stipulations on loading condition and force majeure.
The Contract was concluded based on the two parties' negotiation, which is effective and has binding effect on both parties.
On 23 December 1998, the Contract goods were unloaded at Gaoming port.
On 9 February 1999, the Second Claimant sent the second purchase order to the [Seller] (hereafter, the "Second Purchase Order"), which was confirmed by the [Seller] on 11 February 1999. The Second Claimant acknowledged that it had received the goods in the Second Purchase Order, and that they had been resold to its clients directly without the First Claimant's performance as an import agency.
4. On 2 February 1999, the Second Claimant sent a letter to the [Seller], stating that some clients reported and complained that the plastic part of the ink cartridge and their attachment were of poor quality as compared with the original goods, and that some clients asked whether it was possible to change the type of the goods.
Later, on 25 May 1999, the [Seller] issued an "after-sales guarantee for ink-jet printer cartridges", stating that the Swiss P Group was the largest manufacturer for products used on printers, and that P brand cartridges had excellent quality, and are definitely safe and reliable. The [Seller] promised return or exchange of the goods if it was confirmed that a quality problem on P brand products sold in China was not caused by improper use or other personal reasons.
On 28 May 1999, the Second Claimant sent a letter to the [Seller], stating that it had purchased cartridges from the [Seller] twice and that, within a half-year of sale, many clients claimed quality defects. After calculation, more than 30% of the goods had quality problems. Due to the defects on the goods delivered by the [Seller], many clients asked for the return of the goods, raising that ink leakage had occurred before the packages of the goods were opened. In this letter, the Second Claimant expressed that it was unable to sell ink series products based on creditability, asking to return to the [Seller] the goods stored in the warehouse, which were worth about RMB 200,000.
On the same day that the Second Claimant sent the aforesaid letter (on 28 May 1999), the [Seller] responded that it was surprised to hear the quality defects stated by the Second Claimant, because there had been no such claims in China, Hong Kong, or elsewhere in the world. The [Seller] agreed to investigate and asked the Second Claimant to send two sample defective goods to the [Seller]'s Hong Kong Office, which would be inspected by the inspector in Switzerland and an inspection report would be issued later.
On 4 June 1999, the Second Claimant sent a letter to the [Seller], saying that it had been contacting the [Seller] regarding quality defects, however, the [Seller] did not take it seriously. The [Seller] was surprised only after reading the complaining letters from the clients. The Second Claimant alleged that the practice was the sole criterion for testing truth, and that the consumers were the best quality inspectors. Normally, the manufacturer would immediately send representative to check the situation to solve the problem, but not making judgment based on two sample goods inspected by an engineer. the Second Claimant believed that the [Seller] would not damage its reputation just for RMB ten thousand or something.
On 9 June 1999, CCIB Guangzhou issued an inspection certificate on the cartridges indicating that "the packages for the aforesaid goods were undamaged. After opening the packages, some of the goods had ink leakage. Therefore, since the packages were undamaged, the ink leakage on the part of the cartridges was caused by the goods' intrinsic defects."
(2) The Arbitration Tribunal notes that pursuant to the Contract, the [Buyer] has the right to claim compensation from the [Seller] within 90 days after the goods were unloaded at the destination port by providing an inspection certificate issued by the CCIB. The Claimants raised quality objections within 90 days after the goods were unloaded at Gaoming on 23 December 1998. However, they failed to apply for inspection with the CCIB. Therefore, they were unable to provide an inspection certificate within that time period.
The Arbitration Tribunal also notes that the [Seller] had issued its quality guarantee letter to the Second Claimant prior to the conclusion of the Contract, promising that if it was confirmed that the goods caused any accident, the [Seller] would take the responsibility. And after the conclusion of the Contract, the [Seller] sent a letter to the agent of the Second Claimant, the First Claimant, promising the return or exchange of the goods if defects on the goods were not caused by improper use or other personal reasons. Therefore, the Second Claimant and the [Seller] had not only a distributing relationship but also a sales relationship related to the Contract, and the dispute in this case involves the Contract and a product quality issue related to the Contract.
The Products Quality Law of the People's Republic of China stipulates that:
"1. Seller shall repair, exchange or accept the return of the goods if without explanation in advance, the goods it delivered do not perform the functions they are supposed to perform, or the quality of the goods does not conform to the samples or products descriptions;
"2. Seller shall be responsible for any damages caused to clients or to consumers;
"3. After repair, exchange, or return of the goods or after making compensation for the damages, the [Seller] reserves the right to claim compensation from the manufacturer or the supplier if they are deemed to be responsible."
As an international trade usage adopted commonly, Article 36 of the United Nations Convention on Contracts for the International Sales of Goods (hereafter, the "CISG") stipulates that:
"(1) The [Seller] is liable in accordance with the contract and this Convention for any lack of conformity which exists at the time when the risk passes to the buyer, even though the lack of conformity becomes apparent only after that time.
"(2) The [Seller] is also liable for any lack of conformity which occurs after the time indicated in the preceding paragraph and which is due to a breach of any of his obligations, including a breach of any guarantee that for a period of time the goods will remain fit for their ordinary purpose or for some particular purpose or will retain specified qualities or characteristics."
The Arbitration Tribunal notes that even though the First Claimant failed to claim compensation within the stipulated time by providing the inspection certificate issued by the CCIB, based on related law stipulations, this does not deprive it of its right to file claims on behalf of the Second Claimant on a dispute regarding the goods or the quality of the goods as the agent or the representative of the Second Claimant and as the purchaser and distributor of the goods.
The evidence shows that the clients asked for compensation or the return of the goods for the following defects on the goods:
|-||Severe ink leakage on unopened goods;|
|-||Cartridges were smaller than the original EPSON cartridges, which became loose during printing and were unable to refill ink;|
|-||Ink flow was uneven; lines printed were uneven, which could be erased by eraser;|
|-||Colors were very light, which did not conform to the original colors;|
|-||The ink-jet nozzle could not perform self-inspection, and the ink breaks occasionally.|
At the court session, the Claimants showed various kinds of cartridges. During inspection on site, ink was leaking even though the package was undamaged. The Claimants also provided printings printed by their client, on which printing lines could be erased easily.
Evidence shows that goods of the following types under the Contract had defects:
330895, (7)323303, (7)323626, (7)329554, (7)316950, (7)326637, 318535, 318519, 318527, 316059, 318386, 318394, 322495, 322487, 329227, 329219, 330147.
Based on the quantity of the goods and price listed in the Contract, the price for the aforesaid goods totals 9,734.65 DM.
The Arbitration Tribunal deems that the aforesaid goods have severe defects, which are unable to be used as intended. Based on the Product Quality Law of the PRC and the referenced related stipulations in the CISG, the First Claimant has the right to return the goods, and the [Seller] shall refund the price for the returned goods accordingly.
The evidence shows that the Claimants have paid a transportation fee, customs application fee, loading and unloading fee, import tax, value added tax, L/C modification fee, printing fee, and business representing fee, totaling HK $1,040 and RMB 81,944.45. Based principles of equity, the Arbitration Tribunal holds that the [Seller] shall make compensation based on the percentage of the goods returned (65.9%); therefore, the [Seller] shall compensate the Claimants' transportation fee, customs application fee, loading and unloading fee, import tax, value added tax, and L/C modification fee of HK $685.36 and RMB 19,799.30.
In addition, the printing products manual and engaging business representative were not only for the goods under the Contract, but also for the goods under the Second Purchase Order, therefore, based on the percentage, the [Seller] shall pay the Claimants' printing fee and business representative's salary of RMB 19,495.20.
The Claimants also ask the [Seller] to pay staff traveling fee, office rental fee, telephone bill, and reception fee. However, due to lack of evidence, the Arbitration Tribunal cannot accept these claims.
(3) The First Claimant signed the Contract for the goods under the First Purchase Order on 3 November 1998 as entrusted by the Second Claimant. There is an arbitration clause in this Contract. The Arbitration Tribunal notes that the Order Confirmation for the Second Purchase Order of 11 February 1999 was a confirmation made by the [Seller] after the Second Claimant sent the purchase order. This confirmation does not have an arbitration clause, and it did not mention the Contract or the arbitration clause in the Contract. In addition, it has been ascertained that the goods under the Second Purchase Order were not imported by the First Claimant as entrusted by the Second Claimant.
The Arbitration Tribunal also notes that the [Seller] indicated in its defense that the Arbitration Tribunal could not process claims regarding the goods in the second delivery since there was no arbitration clause. At the court session, the Claimants stated that they filed arbitration claims regarding the second delivery because the amount in dispute in this delivery was small, and they were hoping to process it together with the claim for the Contract without filing a specific claim.
The Arbitration Tribunal understands the Claimants' desire to process the dispute for the second delivery together with the dispute under the Contract. However, the Claimants and the [Seller] failed to stipulate an arbitration clause for the Second Purchase Order. Therefore, the Arbitration Tribunal has no jurisdiction to process or make an award on that dispute. Thus, the Arbitration Tribunal cannot consider the dispute arising from the Second Purchase Order signed by the Claimants and the [Seller]. They may file a separate claim based on law.
(4) Evidence shows that the Claimants have paid attorneys' fee of RMB 13,000. Based on Article 59 of the Arbitration Rules, the [Seller] shall compensate RMB 10,000 to the Claimants.
(5) The arbitration fee for this case is RMB 20,000. The Claimants shall bear 35% of the arbitration fee and the [Seller] shall bear 65%.
III. THE AWARD
The Arbitration Tribunal rules that:
(1) the Claimants shall return to the [Seller] the goods of the types 330895, (7)323303, (7)323626, (7)329554, (7)316950, (7)326637, 318535, 318519, 318527, 316059, 318386, 318394, 322495, 322487, 329227, 329219, 330147 under the Contract worth 9,734.65 DM within ten days of this award, and the [Seller] shall refund the price for these goods accordingly;
(2) [Seller] shall pay the Claimants' loss of HK $685.36 and RMB 19,799.30 within ten days of this award because the goods delivered by the [Seller] were not fit for the business purpose for which the goods would be used;
(3) [Seller] shall pay the printing fee and business representative's salary of RMB 19,495.20 and attorneys' fee of RMB 10,000 to the Claimants within ten days of this award;
(4) The Arbitration Tribunal does not accept the arbitration claims regarding the goods under the Second Purchase Order, and the Claimants may file a claim separately based on law;
(5) The Claimants and the [Seller] should bear the arbitration fee proportionally;
6) The Claimants' other claims are dismissed.
This is the final award.
30 January 2000 in Shenzhen
* All translations should be verified by cross-checking against the original text. For purposes of this translation, the First Claimant of China Guangdong A Company is referred to as [the First Claimant], the Second Claimant of China Guangdong B Company is refereed to as [the Second Claimant], and Respondent of Hong Kong P Company is referred to as [Seller]. Amounts in the currency of the People's Republic of China (renminbi) are indicated as [RMB]; amounts in the former currency of Germany (Deutsche Mark) are indicated as [DM]; amounts in the currency of Hong Kong (dollars) are indicated as [HK $].
** Meihua Xu, LL.M. University of Pittsburgh School of Law on an Alcoa Scholarship. She received her Bachelor of Law degree, with the receipt of a Scholarship granted by the Ministry of Education, Japan, from Waseda University, Tokyo, Japan. Her focus is on International Business Law and International Business related case study.
*** John W. Zhu, LL.M. China University of Political Science and Law (National Graduate Scholarship); Bachelor of Law, Southwest University of Political Science and Law; Double Degree, English Literature, Sichuan International Studies University, Chongqing, China. Focus: International Economic Law.Go to Case Table of Contents