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CISG CASE PRESENTATION

China 20 July 2005 CIETAC Arbitration proceeding (Elevator material case) [translation available]
[Cite as: http://cisgw3.law.pace.edu/cases/050720c1.html]

Primary source(s) of information for case presentation: Case text

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Case identification

DATE OF DECISION: 20050720 (20 July 2005)

JURISDICTION: Arbitration ; China

TRIBUNAL: China International Economic and Trade Arbitration Commission [CIETAC] (PRC)

JUDGE(S): Unavailable

DATABASE ASSIGNED DOCKET NUMBER: CISG/2005/20

CASE NAME: Unavailable

CASE HISTORY: Unavailable

SELLER'S COUNTRY: Switzerland (claimant)

BUYER'S COUNTRY: People's Republic of China (respondent)

GOODS INVOLVED: Elevator materials


Classification of issues present

APPLICATION OF CISG: Yes [Article 1(1)(a)]

APPLICABLE CISG PROVISIONS AND ISSUES

Key CISG provisions at issue: Articles 59 ; 78

Classification of issues using UNCITRAL classification code numbers:

59B [Payment of price due at any time fixed or determinable by contract or Convention: no need for request by seller or other formality];

78B [Rate of interest]

Descriptors: Price ; Interest

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Editorial remarks

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Citations to case abstracts, texts, and commentaries

CITATIONS TO ABSTRACTS OF DECISION

(a) UNCITRAL abstract: Unavailable

(b) Other abstracts

Unavailable

CITATIONS TO TEXT OF DECISION

Original language (Chinese): Unavailable

Translation(English): Text presented below

CITATIONS TO COMMENTS ON DECISION

Unavailable

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Case text (English translation)

Queen Mary Case Translation Programme

China International Economic & Trade Arbitration Commission
CIETAC (PRC) Arbitration Award

Elevator material case [20 July 2005]

Translation [*] by Zheng Xie [**]

Edited by Meihua Xu [***]

The China International Economic and Trade Arbitration Commission (hereafter, the "Arbitration Commission") accepted the case (Case number: M___) according to:

   -    The arbitration clause in Contract No. ZJ-00015 (hereafter, the "Contract") for sales of elevator material signed by Claimant [Seller], ___ Elevator Limited [of Switzerland], and Respondent [Buyer], Zhenjiang ___ Group [of the People's Republic of China], on 30 June, 2000; and
 
   -    The written arbitration application submitted by the [Seller] on 25 January 2005.

The Arbitration Rules of the Arbitration Commission [hereafter, the "Arbitration Rules"], which took effect on 1 October 2000, apply to this case.

On 22 February 2005, the Secretariat of the Arbitration Commission sent the Notice of Arbitration, the Arbitration Rules and the Arbitrators List to both parties by express mail. The Secretariat also sent the Arbitration Application to the [Buyer], and requested the parties to appoint arbitrators within the period provided by the Arbitration Rules, and invited the [Buyer] to submit its opinions and/or counterclaim.

On the same day, as per the [Seller]'s request, the Arbitration Commission forwarded the [Seller]'s Petition for Property Preservation and the Arbitration Application to the Wenzhou City Intermediate People's Court (the "Court") and asked the Court for an order according to relevant laws.

According to Article 16 of the Arbitration Rules, the [Seller] appointed Ms. ___ as its arbitrator. However, Ms. ___ could not accept the appointment; therefore, in the Notice of Arbitration, the Secretariat requested the [Seller] to appoint another arbitrator. Thereafter, because the [Seller] failed to appoint or authorize the Chairman of the Arbitration Commission to appoint another arbitrator, according to Article 26 of the Arbitration Rules, the Chairman appointed Ms. ___ as the arbitrator for the [Seller]. Because the [Buyer] failed to appoint or authorize the Chairman of the Arbitration Commission to appoint an arbitrator, according to Article 26 of the Arbitration Rules, the Chairman appointed Ms. ___ as the arbitrator for the [Buyer]. Since the parties did not appoint or authorize the Chairman of the Arbitration Commission to appoint a Presiding Arbitrator, according to Article 24 of the Arbitration Rules, the Chairman appointed Mr. ___ as the Presiding Arbitrator. On 4 April 2005, the aforementioned three arbitrators formed the Arbitration Tribunal to hear this case.

On the same day, after discussing with the Secretariat, the Arbitration Tribunal decided to open a court session on 10 May 2005 and the Secretariat sent the Notice of Formation of the Arbitration Tribunal and the Notice of the Court Session to both parties.

The Arbitration Tribunal thoroughly reviewed the written material submitted by the parties. On 10 May 2005, the court session was held in Beijing. Both the [Seller] and the [Buyer] sent arbitration agents to attend the court session. Because the parties stipulated in Article 2.2 of the Contract that "the official arbitration language is English or Chinese," with the parties' agreement, the Arbitration Tribunal in the court session decided that Chinese was the official arbitration language of this arbitration. The parties addressed statements, presented and cross-examined evidence, answered the Arbitration Tribunal's questions, and made arguments and statements on the facts and the legal issues.

After the court session, both parties submitted supplemental opinions and evidence. The [Seller] amended its claim for interest and paid an additional arbitration fee for the amended claim. Thereafter, based on the parties' agreement at the court session, the parties cross-examined the supplemental evidence in writing and submitted their final statements to the Arbitration Tribunal.

All arbitration documents were served on the parties.

This case has been completed. The Arbitration Tribunal handed down the award by consent based on the written material submitted by the parties and the facts in the court session

The following are the facts, the Arbitration Tribunal's opinions and the award.

POSSITION OF THE PARTIES

The [Seller]'s Position

On 30 June 2000, the [Seller] and the [Buyer] executed the Contract. (An installation contract was signed by the [Buyer] and Suzhou ___ Elevator Limited, authorized by the [Seller], at the same time.) The Contract between the [Buyer] and the [Seller] stipulated that the [Seller] should sell elevator material for the total price of US $728,390, and also stipulated trade terms, insurance, packing, payment, documents, shipping, quality warranty, inspection, damages, etc.

Article 3 (Payment) of Attachment I to the Contract stipulated:

"The [Buyer] shall pay US $36,419.50, i.e., 5% of the contract price, by T/T within 30 days after receiving a certificate of installation and inspection issued by the local Labor Bureau. However, regardless of whether the Labor Bureau issues a certificate or not, and except the [Seller]'s reasons, the [Buyer] shall pay off the contract price within eight (8) months after the bill of lading for the last shipment."

Article 4 stipulated:

"The [Buyer] can hold 5% of the contract price, i.e., US $36,419.50, for one year's quality guarantee, for at most twenty months."

After signing the Contract, the [Seller] duly performed its duties under the Contract, but the [Buyer] still owed the [Seller] 10% of the contract.

Therefore, the [Seller] submitted the Arbitration Application to the Arbitration Commission according to Article 22 the Arbitration clause of the Contract, and made the following claims:

   1.   The [Buyer] should pay the [Seller] the remaining contract price of US $72,839;
 
   2.   The [Buyer] should pay the [Seller] interest of US $13,957.75 on the delayed payment (as of 31 December 2004); after 31 December 2004, the interest should be calculated as US $72,839 X days overdue X 2.1/10,000/day;
 
   3.   The [Buyer] should compensate the [Seller] for the attorneys' fees, traveling expenses and other expenses incurred due to this case, totaling US $7,283.90;
 
   4. The [Buyer] should bear the arbitration fee.

The [Seller] submitted evidence including the Contract with Attachments, delivery slip, inspection certificate, etc. The [Seller] also provided a written explanation on the aforementioned calculation of interest as follows:

Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10,000 per day from 1 January 2002 to 31 December 2004, is US $36,419.50 1,095 days 2.1 10,000 = US $8,374.65;

Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10000 per day from 1 January 2003 to 31 December 2004, is US $36,419.50 720 days 2.1 10,000 = US $5,583.10;

The total amount of the above two item is US $13,957.75.

The [Buyer]'s Position

1. The [Seller]'s Claim for interest of US $13,957.75 had no ground.

Although the [Buyer] confirmed that it did not pay the remaining contract price of US $72,839, the long time delay of payment was caused by the [Seller]'s failure to perform the duty to cooperate provided in the Contract Law of the People's Republic of China (the "Contract Law"). Article 60 of the Contract Law states:

"The parties shall abide by the principle of good faith, and perform obligations such as notification, assistance, and confidentiality, etc. in light of the nature and purpose of the contract and in accordance with the relevant usage."

In this case, after the performance period stipulated in the Contract expired, the [Buyer] notified the [Seller] numerous times to clear the contract price, but the [Seller] did not respond at all. Because the [Seller] failed to timely cooperate with the [Buyer] to clear and receive the contract price, the [Buyer] could not make the payment. Therefore, the [Buyer] alleged that the [Seller] was responsible for the delay of the payment. In the meantime, even if the [Buyer] owed the [Seller] the contract price, according to Article 119 of the Contract Law, the [Seller] was obligated to take measures to mitigate damages; however, it was unreasonable for the [Seller] to claim interest accrued for such a long time (the longest one was three years), nor did it comply with the principle of good faith.

In addition, neither the Contract nor the Contract Law provides that the [Seller] was entitled to interest on the delayed payment or how to calculate interest. It lacked basis for the [Seller] to calculate interest at the daily rate of 2.1/10,000; in addition, the daily rate of 2.1/10,000 was as high as a penalty, which violated the principle of compensation for civil damages. Even interest provided by law should not exceed deposit interest rate.

2. The [Seller]'s claim of US $7,283.90 for attorneys' fees, traveling expenses and other expenses lacked factual and legal basis.

As to the attorneys' fees, the current Chinese laws do not have relevant provisions, nor did the contract contain such provision. Therefore, the Arbitration Tribunal should not sustain this claim. The traveling expenses were neither proved by facts nor related to this case. Other expenses were ambiguous and lacked any contractual basis; therefore, the Arbitration Tribunal should not sustain the claim for other expenses. In sum, the [Seller] did not submit evidence or calculation method to sustain its claim for US $7,283.90, and the Arbitration Tribunal should dismiss this claim

After the court session, the parties submitted supplemental written opinions.

The [Seller]'s supplemental written opinion

1. Wenzhou City __ Safety Inspection Station

The local labor department confirmed that the Wenzhou City __ Safety Inspection Station used to be an affiliate of Wenzhou Labor Bureau, and is currently a division of the Wenzhou Quality Supervision Bureau.

2. Calculation of interest on the delayed payments

   -    Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10000 per day for 1,277 days from 1 February 2002 to 31 July 2005, is US $36,419.50 1,277 days 2.1 10,000 = US $9,766.62;
 
   -    Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10000 per day for 912 days from 1 February 2003 to 31 July 2005, is US $36,419.50 912 days 2.1 10,000 = US $6,975;
 
   -    The total amount of the above two items is US $16,741.68.

3. The traveling expenses

The traveling expenses were incurred when ___, Esq. with Jiangsu Suzhou ___ Law Firm went to Hangzhou, Zhejiang Province and Wenzhou to investigate on the status of the [Buyer] and negotiate for settlement.

4. The attorneys' fees

The attorneys' fees were determined based on attorneys' fees standard and the client and the attorneys' agreement. The attorneys and the [Seller] executed an Engagement Agreement. This Engagement Agreement did not violate the attorneys' fees standard implemented in Jiangsu Province.

5. The starting payment date

Article 3 (Payment) of Attachment I to the Contract stipulated:

"The [Buyer] shall pay US $36,419.50, i.e., 5% of the contract price, by T/T within 30 days after receiving a certificate of installation and inspection issued by the local Labor Bureau."

This payment term was definite. It also provided, "However, regardless of whether the Labor Bureau issues a certificate or not, and except the [Seller]'s reasons, the [Buyer] shall pay off the contract price within eight (8) months after the bill of lading for the last shipment," because some customers do not immediately install elevators after purchasing elevators material, and inspection and acceptance cannot be conducted, and therefore, the payment cannot be made. In order to avoid the situation that some customers, intentionally or because of some objective reasons, could not install or inspect the elevators, and the [Seller] could not receive the payment, the parties agreed that if the elevators were not installed, the payment should be made within the stipulated period after the last shipment was delivered.

Therefore, when the local labor bureau issued a quality certificate on installation and acceptance, the [Buyer] should have made payments of 5% of the contract price and 5% of the quality deposit within the stipulated period from the date of the local labor bureau's issuance of the certificate.

6. Explanation on the wrongful date of execution

The quality certificate for the six elevators was dated 22 December 2002. This was a typo. The Delivery Slip dated 11 April 2002 clarified that the inspection report had been delivered to the [Buyer], and during the cross-examination, the [Buyer] expressly confirmed that it received the quality certificate.

The [Buyer]'s supplemental written opinion

1. After the elevator material was delivered, the [Buyer] should pay 5% of the contract price, i.e., US $36,419.50, before 11 December 2002. Article 3 (Payment) of Attachment I to the Contract stipulated, "The [Buyer] shall pay US $36,419.50, i.e., 5% of the contract price within eight (8) months after the bill of lading for the last shipment." The [Seller] provided the delivery slip to the [Buyer] the afternoon of 11 April 2002. According to the aforementioned Article 3 (Payment), the [Buyer] should have paid this amount before 11 December 2002, i.e., within eight (8) months after the [Seller] delivered the last shipment. Therefore, the allegation that the payment of 5% of the contract price should have been made in January 2002 did not comply with the stipulation in the Contract.

2. The quality deposit should be paid before 11 December 2003.

Article 4 of Attachment I of the Contract stipulated:

"The [Buyer] can hold 5% of the contract price, i.e., US $36,419.50, for one year's quality guarantee, for at most 20 months after the issuance of the B/L."

The quality certificate for the six elevators was dated 22 December 2003. Based on this date, the qualify deposit should have been paid on 11 December 2003. Therefore, the [Seller]'s allegation that the quality deposit should be paid on 1 January 2003 did not comply with the stipulation in the Contract.

3. The [Seller] was responsible for the non-payment of the above two amounts.

THE ARBITRATION TRIBUNAL'S OPINION

1. Applicable law

The Contract stipulated that "the Contract shall be governed pursuant to the laws of the People's Republic of China." The parties did not dispute this.

The Arbitration Tribunal noted that the [Seller]'s place of business and the [Buyer]'s place of business were in China and Switzerland, respectively. Both China and Switzerland are Contracting States of the United Nations Convention on Contracts for International Sales of Goods ("CISG"), and the parties did not exclude the application of the CISG. Therefore, the CISG also applies to this case except where the laws of the People's Republic of China apply.

2. The [Seller]'s claim for the unpaid contract price

The [Seller] alleged that it had performed its duties under the Contract, but the [Buyer] failed to pay the full contract price, and still owed 10% of the contract price. The [Seller] submitted the delivery slip and the quality certificate to support its claim. During the cross-examination, the [Buyer] admitted the Contract, the delivery slip, the quality certificate, etc. Therefore, this evidence was admissible to prove the debts between the parties. In addition, in its Response the [Buyer] admitted that it did not pay the contract price of US $72,839. Therefore, the Arbitration Tribunal sustained the [Seller]'s claim for the contract price.

However, while admitting the non-payment of the contract price, the [Buyer] alleged that this long time non-payment was also caused by the [Seller]'s failure to perform its duty to cooperate as provided in the Contract Law. After the stipulated period of performing the Contract expired, the [Buyer] notified the [Seller] to clear the contract price many times, but the [Seller] did not respond at all; the [Seller] did not timely clear and accept the payment, which caused the non-payment of the contract price until present.

The Arbitration Tribunal held that the [Buyer]'s aforesaid allegation lacked legal basis. Article 161 of the Contract Law provides:

"The buyer must pay the price on the date fixed by or determinable from the contract."

The Contract stipulated the time for the two payments of 5% of the contract price each, and it is not ambiguous. As to the payment method, the first 5% of the contact price should be paid by T/T, and the second one should be paid as refund of qualify deposit. There is no special arrangement for the payment method.

Article 59 of CISG provides:

"The buyer must pay the price on the date fixed by or determinable from the contract and this Convention without the need for any request or compliance with any formality on the part of the seller."

This provision of CISG is consistent with the Article 161 of the Contract Law, and both provisions provide that it is the buyer's legal duty to pay the contract price on time, and the provision of CISG provides this duty more specific, i.e., the buyer shall perform this duty "without the need for any request or compliance with any formality on the part of the seller." Therefore, the provision of CISG excludes any excuse of the buyer to delay the payment of the contract price. This can expedite the payment process and mitigate disputes. The [Buyer] alleged that the non-payment of the contract price was caused by the [Seller]'s failure to cooperate. This allegation was not consistent with the provision of the Contract Law or the provisions of the CISG. Therefore, the Arbitration Tribunal did not sustain the [Buyer]'s allegation.

3. Interest on the unpaid contract price

The [Buyer] alleged that neither the Contract nor the Contract Law provided that "the [Seller] is entitled to interest on the delayed payment, or how to calculate interest." However, the Arbitration Tribunal held that it is well recognized in the industry that interest should be paid on the overdue amount, because one party delayed the payment, which was actually to use the other party's funds, and interest accrued for the other party's cash flow. Therefore, interest is compensation to the creditor for the overdue period. This is purpose of Article 78 of CISG, i.e.,

"If a party fails to pay the price or any other sum that is in arrears, the other party is entitled to interest on it, ..."

The purpose of compensating the creditor for interest on the overdue debt is to force the debtor to pay the outstanding debt as soon as possible in order to avoid the accrual of interest. The ]Buyer] did not discuss this purpose, but only emphasized that the [Seller] was obligated to mitigate damages, and alleged that "it was unreasonable for the [Seller] to claim interest accrued for such a long time (the longest one was three years), nor did it comply with the principle of good faith." This allegation is incorrect, and was not sustained by the Arbitration Tribunal.

As to the interest rate, referencing the Supreme Court's Response on the Standards to Calculate Liquidated Damages on Overdue Payment (Fa Shi [1999] No. 8) and Article 6 of China People's Bank's Notice to Lower Deposit Interest Rate and Load Rate, the Arbitration Tribunal held that the daily interest rate of 2.1/10,000 was reasonable.

4. The interest accrual period and the total amount

The [Seller] claimed the interest calculated as follows:

   -    Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10,000 per day from 1 January 2002 to 31 December 2004, is US $36,419.50 1,095 days 2.1 10,000 = US $8,374.65;
 
   -    Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10,000 per day from 1 January 2003 to 31 December 2004, is US $36,419.50 720 days 2.1 10,000 = US $5,583.1;
 
   -    The total amount of the above two items was US $13,957.75 as of 31 December 2004. The interest accrued thereafter should be calculated as US $72,839 X 2.1/10,000 X days overdue.

Thereafter, the [Seller] revised the interest on the first 5% of the contract price as follows:

   -    Interest on the delayed payment of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10,000 per day for 1,277 days from 1 February 2002 to 31 July 2005, is US $36,419.50 1,277 days 2.1 10,000 = US $9,766.62;
 
   -    Interest on the delayed payment of the quality deposit in the amount of US $36,419.50, i.e., 5% of the contract price, calculated at 2.1/10,000 per day for 912 days from 1 February 2003 to 31 July 2005, is US $36,419.50 912 days 2.1 10,000 = US $6,975;
 
   -    The total amount of the above two items is US $16,741.68.

With respect to the [Seller]'s above calculation, the [Buyer] alleged that based on "within eight months of delivery of the last shipment, the two payment should have been made on 11 December 2002 and 11 December 2003, respectively.

The Arbitration Tribunal found that Article 3 (Payment) of Attachment I to the Contract stipulated, "the [Buyer] shall pay US $36,419.50, i.e., 5% of the contract price, by T/T within 30 days after receiving a certificate of installation and inspection issued by the local Labor Bureau. However, regardless of whether the Labor Bureau issues a certificate or not, and except for the [Seller]'s reasons, the [Buyer] shall pay off the contract price within eight (8) months after the bill of lading for the last shipment." Article 4 stipulated, "the [Buyer] can hold 5% of the contract price, i.e., US $36,419.50, for one year's quality guarantee, for at the most twenty months after receiving the B/L."

The above attachment stipulated two ways to decide the payment time, and both ways were valid. The [Seller] provided the quality certificate issued by the local labor bureau on 4 March 2002, and also provided the delivery slip which showed the start of the warranty period. The [Buyer] alleged that the starting date should be the day when the bill of lading was delivered, but it did not provide the essential evidence -- the bill of lading -- and therefore, it could not be calculated. The Arbitration Tribunal held that the starting date should be the day when the delivery slip was delivered. It was calculated as follows:

      (1) Interest on the first 5% of the contract price

      According to Article 3 (Payment) of Attachment I, "the [Buyer] shall pay US $36,419.50, i.e., 5% of the contract price, by T/T within 30 days after receiving a certificate of installation and inspection issued by the local Labor Bureau." The delivery slip stated that "the quality certificated was issued on 4 March 2002." The quality certificate was issued by Wenzhou City ___ Safety Inspection Station. The [Seller] explained "Wenzhou City ___ Safety Inspection Station used to be an affiliate of Wenzhou Labor Bureau, and is currently a division of Wenzhou Quality Supervision Bureau." The [Buyer] did not object to this. The quality certificate was issued on 4 March 2002, and thirty days were added; therefore, the overdue days on this payment were 1,002 days from 3 April 2002 to 31 December 2002. The interest should be calculated as US $36,419.50 1,002 2.1/10,000 = US $7,663.39.

      (2) Interest on the refund of quality deposit (5% of the contract price)

      According to the delivery slip, the warranty period started from 4 March 2002, and the quality deposit should be refund after the one-year warranty expired. The overdue days were 667 days from 4 March 2003 to 31 December 2004. The interest should be calculated as follows: US $36,419.50 667 2.1/10,000 = US $5,101.28

      (3) Interest accrued after 31 December 2004

      Considering the payment method stipulated in the Contract and based on the principle of fairness, the Arbitration Tribunal held that it was reasonable that the interest on overdue amount was calculated to 31 December 2004, and thereafter no interest should be paid.

In view of the above, the [Buyer] should pay the [Seller] interest of US $12,764.67.

5. The [Seller]'s claim for the attorneys' fees, traveling expenses, etc.

The [Seller] claimed attorneys' fees, traveling expenses, etc., but did not provide any relevant evidence. The [Seller] alleged:

"The attorneys' fees were determined based on attorneys' fees standard and the client and the attorneys' agreement. The attorneys and the [Seller] executed an Engagement Agreement. This Engagement Agreement did not violate the attorneys' fees standard implemented in Jiangsu Province."

However, the [Seller] did not provide an official receipt of the attorneys' fees. As to other expenses, the [Seller] did not submit any invoice, so it did not prove that the alleged expenses were really incurred. The Arbitration Tribunal did not sustain this claim.

6. The arbitration fee

Considering the situation of this case, and the extent to which the Arbitration Tribunal supports the two parties claims, the Tribunal held that the [Seller] should pay 30% of the arbitration fee, and the [Buyer] should pay 70%.

AWARD

The Arbitration Tribunal handed down the following award:

   1.   The [Buyer] shall pay the [Seller] the overdue amount of US $72,830;
 
   2.   The [Buyer] shall pay the [Seller] interest of US $12,764.67 on the overdue amount.
 
   3.   The [Seller]'s other claims were dismissed.
 
   4.   The arbitration fee was RMB 38,139, of which the [Seller] shall bear 30%, i.e., RMB 11,441.70, and the [Buyer] shall pay 70%, i.e., RMB 26,697.30. The [Seller] had already prepaid the entire arbitration fee, so the [Buyer] shall pay the [Seller] RMB 26,697.30.

This award is final. It took effect when handed down.


FOOTNOTES

* All translations should be verified by cross-checking against the original text. For purposes of this translation, Claimant of Switzerland is referred to as [Seller]; Respondent of the People's Republic of China is referred to as [Buyer]. Amounts in the currency of the United States (dollars) are indicated as [US $]; amounts in the currency of the People's Republic of China (renminbi) are indicated as [RMB].

** Zheng Xie, LL.M. Washington University in St. Louis, LL.M., BA in Economics, University of International Business and Economics, Beijing.

*** 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 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.

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