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CISG CASE PRESENTATION

China 8 March 1996 CIETAC Arbitration proceeding (Horsebean case) [translation available]
[Cite as: http://cisgw3.law.pace.edu/cases/960308c2.html]

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

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Case identification

DATE OF DECISION: 19960308 (8 March 1998)

JURISDICTION: Arbitration ; China

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

JUDGE(S): Unavailable

DATABASE ASSIGNED DOCKET NUMBER: CISG/1996/13

CASE NAME: Unavailable

CASE HISTORY: Unavailable

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

BUYER'S COUNTRY: France (claimant)

GOODS INVOLVED: Horsebeans


Case abstract

PRC: China International Economic & Trade Arbitration Commission,
Horsebeans case of 8 March 1996

Case law on UNCITRAL texts (CLOUT) abstract no. 680

Reproduced with permission of UNCITRAL

Abstract prepared by Anna Lin

A French buyer and a Chinese seller entered into a sales contract on horsebeans with the price term FOB Tianjin. The contract stipulated that the Import & Export Commodity Inspection Bureau of the People's Republic of China should inspect the goods before delivery to Egypt.

The buyer had informed the seller that it had contracted to resell the horsebeans to the Military of Egypt. To simplify the delivery, the buyer had in vain tried to make the inspection by Egyptian inspectors in Tianjin part of the parties' agreement. Nevertheless, the seller allowed the Egyptian inspectors to inspect the first delivery (approximately two thirds) of the goods in the warehouse in Tianjin. Most of the goods passed the inspection, but the Egyptian inspectors violated the warehouse rules. After that the seller refused to submit the remainder of the goods to the Egyptian inspectors. However, it notified the seller that the goods had been prepared. The buyer refused to take delivery without the Egyptian inspection before and sought damages in an arbitration proceeding, alleging that the seller had fundamentally breached the contract by not submitting all goods to the Egyptian inspectors.

The arbitral tribunal held that, in absence of a contract clause, CISG was the applicable law, since the places of business of both parties were in CISG contracting States [Art. 1(1)(a) CISG]. The tribunal noted that the seller's behaviour to allow the inspection of part of the goods by the Egyptian inspectors did not mean acceptance of inspection for all the goods, but was a mere act of cooperation [Art. 8 CISG]. Further, the tribunal decided, pursuant to Art. 30 and 60 CISG, that the seller's refusal to allow inspection by the Egyptian inspectors did not constitute a fundamental breach of contract [Art. 25 CISG], since the contract only required the inspection by the Chinese Inspection Bureau. On the contrary, the tribunal considered the buyer's failure to make arrangements for taking delivery of the goods a fundamental breach of contract. Consequently, the buyer's claims for compensation were dismissed.

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Classification of issues present

APPLICATION OF CISG: Yes

APPLICABLE CISG PROVISIONS AND ISSUES

Key CISG provisions at issue: Articles 8 ; 25 ; 30 ; 60

Classification of issues using UNCITRAL classification code numbers:

8C [Interpretation in light of surrounding circumstances];

25B [Definition of fundamental breach: substantial deprivation of expectation, etc.];

30A [Summary of seller's obligations: obligation to deliver the goods];

60A [Buyer's obligation to take delivery: includes acts reasonably expected to aid seller]

Descriptors: Intent ; Fundamental breach ; Delivery ; Incoterms

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Editorial remarks

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Citations to other abstracts, case texts and commentaries

CITATIONS TO OTHER ABSTRACTS OF DECISION

Unavailable

CITATIONS TO TEXT OF DECISION

Original language (Chinese): Zhong Guo Guo Ji Jing Ji Mao Yi Zhong Cai Wei Yuan Hui Cai Jue Shu Hui Bian [Compilation of CIETAC Arbitration Awards] (May 2004) 1996 vol., pp. 957-963

Translation (English): Text presented below

CITATIONS TO COMMENTS ON DECISION

English: Dong WU, CIETAC's Practice on the CISG, at n.120, Nordic Journal of Commercial Law (2/2005)

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Case text (English translation)

Queen Mary Case Translation Programme

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

Horsebeans case (8 March 1996)

Translation [*] by Meihua Xu [**]

Edited by Liming (Anna) Lin [***]

The China's International Trade and Economic Arbitration Commission Shanghai Commission (hereafter, the "Shanghai Commission") accepted the case according to:

   -    The arbitration clause in Sales Contract No. (95)JUA002 signed by Claimant [Buyer], France __ Trade Company, and Respondent [Seller], China Jiangsu __ Import & Export Company, on 3 November 1995; and
 
   -    The written arbitration application submitted by [Buyer] on 22 November 1995.

The [Buyer] appointed Mr. P as its arbitrator. After receiving the arbitration notice and the [Buyer]'s arbitration application document sent by the Shanghai Commission, the [Seller] negotiated with the [Buyer], and on 23 December 1995, both parties signed an agreement, appointing Mr. P as the sole arbitrator in this case.

The parties submitted written documents stating that the case was qualified for summary procedure with the Shanghai Commission pursuant to Articles 64 and 65 of the Arbitration Rules. On 5 January 1996, the Shanghai Commission authorized Mr. P, the sole Arbitrator jointly appointed by the parties, to form the Arbitration Tribunal to hear this case.

The Arbitration Tribunal examined the arbitration application submitted by the [Buyer], the arbitration defense submitted by the [Seller] and other attached documents. On 12 February 1996, a court session was held in Shanghai. The President of the [Buyer]'s firm, the representative of the [Buyer], and the representative of the [Seller] appeared at the court session. They presented statements, made arguments, and answered the Arbitration Tribunal's questions.

During the court session, the Arbitration Tribunal sought to mediate the dispute between the parties after receiving their agreement. This effort did not succeed.

After the court session, both parties submitted supplementary documents. This case has been concluded and the Arbitration Tribunal made this award. The following are the facts, the Tribunal's opinion and award.

I. FACTS

[Buyer]'s position

The [Buyer] alleges that:

On 16 February 1995, the [Buyer] unilaterally sealed and signed Contract No. (95) JUA002 and on the same day faxed it to the [Seller] (which was at that time called Jiangsu __ Import & Export Group). According to the contract, the [Buyer] agreed to purchase 2,000 to 3,000 MT of horsebeans (with the exact quantity to be determined by the [Seller]). The contract stated:

   -    Specifications: Water content of the horsebeans: should not exceed 15%, Impurity should not exceed 2%, the shipment should contain no live insects or hemp seed;
 
   -    Price term: Unit price is US $224/MT, FOB S Tianjin; the total price is between US $448,000 and $672,000;
 
   -    Delivery date: Before March 1995;
 
   -    Payment term: The [Seller] should receive from the [Buyer] an irrevocable and transferable L/C twenty days before the delivery, (or the [Buyer] may issue the L/C within fifteen days after it receives the [Seller]'s notice, and the L/C's expiration date should be fifteen days after the delivery day);
 
   -    Inspection: It was determined in Article 6 on the backside of the contract that the Import & Export Commodity Inspection Bureau of the People's Republic of China should inspect the quality and quantity of the goods;
 
   -    Remarks: The total price should include the inspector's local expenses. This cost should not exceed renminbi [RMB] 50,000 (if the quantity is 2,000MT) or RMB 70,000 (if the quantity is 3,000MT). The aforesaid sum should be paid in US dollars after the [Buyer] receives the amount of goods as stipulated in the contract.

After receiving the aforesaid contract, the [Seller] did not raise any objection, and on 15 February 1995, the [Buyer] issued the L/C. Following multiple discussions, the L/C was modified with the agreement of the [Seller] to set the quantity of the goods at 2,000MT, and the delivery date on 21 March 1995.

Later, the [Buyer] sent a team of Egyptian inspectors to inspect the goods that were to be delivered. By the end of February of 1995, they had inspected 1,227.8MT of the goods, of which 987.9MT passed their inspection.

The [Buyer] and the [Seller] could not reach an agreement on the issues of preparing, inspection and shipping arrangements for the remaining 800MT of goods, with the result that the contract could not be performed.

The [Buyer] alleges that:

   -    The fundamental reason that the contract could not be performed was because of the [Seller]'s failure in preparing the goods, and the [Seller] should take the entire responsibility for this failure.
 
   -    The [Seller] has fundamentally breached the contract, which has violated international trade usages and caused severe economic loss to the [Buyer].
 
   -    The [Seller] should compensate all of the economic loss to the [Buyer].

The parties could not settle the dispute by negotiation; therefore, the [Buyer] filed this arbitration application to the Shanghai Commission, claiming

1. Because the [Seller] refused to deliver the goods, it should bear the [Buyer]'s cost of purchasing replacement goods: US $138,600;

2. [Seller] should bear the cost of issuing and modifying the L/C: US $130.46;

3. [Seller] should bear the cost of sending inspectors from Egypt: US $40,200;

4. [Seller] should bear the penalty paid to the Military of Egypt for the delay of delivery: US $58,674;

5. In total, [Seller] should compensate US $237,604.46 to the [Buyer] and should bear the entire arbitration fee.

The [Buyer] also asserts that:

1. [Buyer] issued the L/C on time and has repeatedly urged the [Seller] to prepare the remaining 800MT of goods to be inspected by the Egyptian inspectors. However, the goods were never presented to the Egyptian inspectors for inspection.

On 23 March 1995, the [Seller] gave notice to the [Buyer] through Mr. W of A International Trade Company (hereafter, "A Company") stating that the goods had been delivered to the departure port, however, the [Seller] failed to provide sufficient evidence to show that the entire amount of goods had been delivered to Tianjin warehouse before 21 March 1995. Therefore, the [Buyer] had reason to believe that the [Seller] did not prepare the entire quantity of goods and failed to perform its obligation to deliver the goods.

2. It was stipulated in the Remarks section of the contract that the total price of the contract included the local expenses of the inspectors from Egypt, which should be paid in US dollars after the [Buyer] received the entire quantity of goods. Therefore, the [Seller]'s argument that the price was only for the goods, and that the cost of the inspection by Egyptian inspectors was beyond the rights and obligations determined in the contract is not true and breaks the [Seller]'s own promise.

The contract goods were to be resold to the Military of Egypt, and the goods were to be delivered directly to the port in Egypt, which was acknowledged by the [Seller].

Under Egyptian law, all foods imported must be inspected by the Agriculture or Sanitary Department before entering Egypt. In order to deliver the goods without difficulty, the [Buyer] suggested to have the goods inspected by the Egyptian Inspectors first, without which the good could not be imported smoothly and the contract would become meaningless.

During the formation and the performance of the contract, the [Seller] had never raised objection to having the goods inspected by Egyptian inspectors. In addition, from the letters the [Seller] sent to the [Buyer], it could be found that the [Seller] had accepted that having goods inspected by the Egyptian inspectors was a condition before shipment.

The inspection by Egyptian inspectors does not conflict with the inspection by the Import & Export Commodity Inspection Bureau of the People's Republic of China. This was not only for importing the goods smoothly, but also a key point for performing the contract, which should be cooperated in by the [Seller] and it was the [Seller]'s obligation to do so.

3. The [Seller]'s performance of the contract indicated that the purpose of refusing to deliver the goods and avoiding having the goods inspected by the Egyptian inspectors was to increase the price of the goods. The [Seller]'s demand for a higher price was to impute to the [Buyer] the loss caused by its supplier's violation of the contract between the [Seller] and its supplier, which is not a remedy for the contract.

In addition, a higher price was demanded by [Seller] before announcing the avoidance of the contract, which indicated that demanding a higher price was not for concluding a new contract. The [Seller]'s reason for refusing to deliver the goods before the contract even being modified or terminated was to force the [Buyer] to accept its higher price, which has constituted a contract violation and has violated the [Buyer]'s legal rights.

4. The [Buyer] could reserve shipping only after the [Seller] prepared 2,000MT of goods and after the goods were inspected by the Egyptian inspectors, otherwise, it could only cause the [Buyer] to pay a high reservation fee and to pay a penalty for the delay in loading.

The [Buyer] has performed the contract properly and has informed the [Seller] and its representative, Mr. W of A Company, about the reservation of the shipping, however, the [Seller]'s delay in preparing the goods for inspection caused the [Buyer]'s delay in arranging shipment, with the result that the [Buyer] has suffered severe economic loss and was asked for compensation by the shipping company, BISSMAS, A. There was no fault of the [Buyer] in arranging shipping; the [Seller]'s assertion to the contrary has no legal basis.

5. The [Seller]'s allegation that Mr. W of A Company was only a middleman in this case is not true. Before the contract was concluded, Mr. W was the middleman who contributed to the conclusion of the contract. However, after the conclusion of the contract, which was 16 February 1995, Mr. W became the representative of the [Seller], and all the letters sent by him represented the [Seller].

6. The claim for compensation stated in the [Buyer]'s arbitration application is only the most direct economic loss to the [Buyer], which did not include the [Seller]'s contract violation fee, compensation, nor the [Buyer]'s attorneys' fee, traveling fee, and the loss of profit.

[Seller]'s defense

The [Seller] counter argues that:

1. The [Buyer]'s assertion in its arbitration application that the [Seller] failed to deliver the remaining 800MT of goods to Tianjin warehouse is erroneous. The fact is that 1,227MT of goods were delivered to Tianjin warehouse at the end of March 1995, and the remaining 800MT of goods were also delivered to the same warehouse on 21 February 1995. By 21 March 1995, the [Seller] had fulfilled its obligation to deliver the entire quantity of contract goods. Afterwards, the [Seller] and Mr. W had repeatedly informed the [Buyer] that the goods had been prepared for shipment by the [Buyer], therefore, the [Buyer]'s assertion that the [Seller] failed to give notice to the [Buyer] about the quantity of the goods and that the entire quantity of goods was not prepared to be shipped has no basis.

2. The [Buyer] and the [Seller] did not reach agreement on the issue of inspection by Egyptian inspectors. It was stipulated in the contract that the Import & Export Commodity Inspection Bureau of the People's Republic of China should confirm the quantity and quality of the goods. This was the only inspection clause in the contract; it indicates that both parties agreed that the inspection result by the inspection agency specified should be the basis for the quality and quantity of the goods and no other stipulation about inspection should exist.

During the negotiation of the L/C, the [Buyer] tried to make the inspection certificate issued by the Egyptian inspectors one of the documents required, but this was rejected by the [Seller]. The [Buyer]'s allegation that the goods should be inspected by Egyptian inspectors is not true and adding this as a requirement is contrary to the contract.

The Remarks section of the contract had to do with the price and payment term, which did not affect the stipulation and the effectiveness of the inspection clause. Egyptian inspectors coming to Tianjin to inspect the goods before the goods were loaded was determined in the contract between the [Buyer] and its customer in Egypt, which was the obligation the [Buyer] should perform to its customer and was beyond the rights and obligations determined in the contract between the [Buyer] and the [Seller].

The [Seller]'s giving cooperation to the Egyptian inspectors was to cooperate with the [Buyer], but was not the [Seller]'s obligation. The [Buyer] has mixed the two different rights and obligations, and its assertion that both parties agreed to have the goods inspected by the Egyptian inspectors was only the [Buyer]'s subjective judgment without any basis.

3. According to the contract and international trade usages, and under FOB terms, the [Buyer] has the obligation to rent, make reservation, and send the ship to accept the goods and the obligation to give shipping notice to the [Seller]. However, by the end of the delivery date, the [Seller] had not received any notice from the [Buyer]. Even without receiving such notice from the [Buyer], the [Seller] informed the [Buyer] that the goods had been prepared, but the [Buyer] refused to perform its obligation to arrange shipment and to receive the goods, saying that the [Seller] had not prepared the goods and that the goods had not been inspected by the Egyptian inspectors and using this excuse to postpone the shipping date in the L/C.

The [Buyer]'s behavior has violated the contract and international trade usages. This has constituted a fundamental breach of the contract. It also violated the basic principal in international trade, being honest and following the contract.

4. According to related laws and international regulations, as a contract performing party, the [Seller] has the right to resort to remedies, dispose of goods, and claim for compensation when the [Buyer] has fundamentally breached the contract.

Regarding the fact that the [Buyer]'s breach of contract has caused severe economic loss to the [Seller], the [Seller]'s demanding higher price on 6 April 1995 was exercising its aforesaid right and was legal and not, as the [Buyer] said, in violation of the contract.

5. The [Buyer]'s nonperformance of the contract caused a fundamental breach of the contract, which deprived the [Buyer] of the right for compensation. The [Seller] has performed the contract properly. The [Buyer] should take all the responsibility for contract violation.

The [Seller] asks the Arbitration Tribunal to rule that:

  1. All of the [Buyer]'s claims should be dismissed;.

  2. [Buyer] should pay the [Seller]'s attorneys' fee and all other costs of US $15,000;

  3. [Buyer] should bear the entire arbitration fee.

II. OPINION OF THE ARBITRATION TRIBUNAL

The Arbitration Tribunal examined the relevant documents and evidence and concludes that:

1. On 16 February 1995, the [Buyer], France __ Trade Company, signed Contract No. (95) JUA002 and faxed it to the [Seller], Jiangsu __ Import & Export Company, which raised no objection. During the court session, the parties agreed that the contract had been formed and that it was binding on both parties.

Applicable law

The parties did not stipulate the applicable law either before signing the contract or after the dispute arose. Considering the fact that the two countries where both parties are located are Contracting States of the United Nations Convention on Contracts for the International Sales of Goods (hereafter, "the CISG"), the Arbitration Tribunal deems that this case should be decided based on the CISG, referring to international trade usages.

[Essential elements of the dispute]

2. The essential part of this dispute is which party has fundamentally breached the contract which caused that the contract could not be performed. The Arbitration Tribunal deems that the [Seller] has fulfilled its obligation to deliver the goods, but the [Buyer] did not arrange for shipment, with the result that the contract could not be performed.

[Delivery of the goods]

First, it has been confirmed that after modifying the L/C, the quantity of the goods is 2,000MT and the delivery date was 21 March 1995, and that the [Seller] delivered 1,227.8MT of goods to Tianjin warehouse at the end of February, and delivered the remaining 800MT goods before 31 March 1995. The [Seller] first informed the [Buyer] that 800MT goods were to be delivered around 22 March, and, through Mr. W of A Company, later gave notice to the [Buyer] that 2,000MT of goods had been prepared to be shipped. The [Buyer]'s assertion that the [Seller]'s not giving notice directly to the [Buyer] caused the [Buyer] to believe that the [Seller] was not able to deliver the remaining goods has no basis, and should not be accepted.

[Inspection of the goods]

Secondly, about the inspection of the goods. The Arbitration Tribunal deems that it is clearly determined in Article 6 on the backside of the contract that the Import & Export Commodity Inspection Bureau of the People's Republic of China should confirm the quantity and the quality of the goods and it should be the basis for inspecting goods.

It was stipulated in the Remarks section of the contract that the total price included the local expenses of the inspector (it should be renminbi [RMB] 50, 000 if the quantity is 2, 000MT, and RMB 70, 000 if the quantity is 3, 000MT), which should be paid after the entire quantity of contract goods was received by the [Buyer]. However, the issue of having goods inspected by the Egyptian inspectors was not clear. The Arbitration Tribunal notes that during the negotiation, the [Buyer] demanded adding the inspection certificate issued by the Egyptian inspectors as one of the required documents, a demand that was rejected by the [Seller]. The [Seller] insisted that inspection should be performed by the Import & Export Commodity Inspection Bureau of the People's Republic of China. This was agreed to by the [Buyer] and the requirement regarding Egyptian inspectors was deleted from the L/C.

The [Buyer] had informed the [Seller] that the goods were to be sold to the Military of Egypt, and under the law of Egypt, an inspection certificate was needed for the goods to enter into Egypt. The sale was introduced by the middleman, and the [Buyer]'s allegation that the [Seller] should have known and accepted having the goods inspected by the Egyptian inspectors before loading lacks basis.

In addition, the shipping clause in the contract did not indicate that the goods must be inspected by the Egyptian inspectors before loading. The Egyptian inspectors have inspected 1,227.8MT of contract goods, which did not mean that accepting the inspection was the obligation of the [Seller]. It was only an act of cooperation by the [Seller].

The Egyptian inspectors violated the regulations of the warehouse, and were rejected and fined by the management of the warehouse. The [Seller]'s refusal to have goods inspected by the Egyptian inspectors did not violate the contract.

[Status of Mr. W of A Company]

The inspection of the goods is connected with the position and effect of the actions of Mr. W of A Company. The [Buyer] alleges that Mr. W is the representative of the [Seller], who admitted the Egyptian inspectors' inspection, which indicated that the [Seller] agreed to have the goods inspected by the Egyptian inspectors.

From the documents Mr. W provided to the Shanghai Commission and the letters Mr. W submitted to the Chinese Embassy in France, it could be found that Mr. W was the middle man for negotiating and performing the contract throughout. Mr. W asserts that unless it was clearly stated in the letters sent by him that he was entrusted by one party to make any promise, the letters were sent just to help concluding the contract by understanding one party's demand and trying to convince the other party to accept that demand. Therefore, the Arbitration Tribunal deems that the [Buyer]'s assertion that Mr. W's accepting having goods inspected by the Egyptian inspectors indicated that the [Seller] also accepted this demand is not correct.

[Obligations of the parties]

Thirdly, the price term in this contract was FOB Tianjin. According to Incoterms 1990, the [Buyer] must give notice to the [Seller] of the ship's name, loading location, and loading time. The [Buyer] and the [Seller] decided that the shipping date would be in March 1995, therefore, the [Buyer] should have reserved and sent the ship to Tianjin, especially after Mr. W sent notice to the [Buyer] on 23 March 1995, stating that the goods had been prepared, and the [Seller] confirmed the aforesaid fact.

The [Buyer] had no reason to doubt whether the [Seller] had prepared the entire quantity of goods, nor did it have reason to insist upon reserving the ship only after the goods were inspected by the Egyptian inspectors. Even though the [Buyer] arranged shipment afterwards, as it could not accept delivery on 31 March 1995, this was a fundamental breach of the [Buyer]'s obligation to accept the goods. Since the [Buyer] did not perform its obligation to accept the goods, the [Seller] had the right to seek remedies for the contract goods.

Above all, according to Article 30 of the CISG, which says that "the [Seller] must deliver the goods as required by the contract and this Convention", Article 60 of the CISG, which stipulates that the buyer shall do "all the acts which could reasonably be expected of him in order to enable the seller to make delivery", and the explanation of FOB in Incoterms 1990, the Arbitration Tribunal deems that the [Seller] has fulfilled its obligation to deliver the goods, however, the [Buyer] failed to make arrangement for shipping, which caused that the contract could not be performed. The [Buyer] did not provide support for its arbitration claim, therefore, all of the [Buyer]'s claims are dismissed.

3. The [Seller] claimed for its attorneys' fee and other costs of US $15,000. Since the [Seller] did not file its arbitration counterclaim following the Arbitration Rules, the Arbitration Tribunal did not consider this claim.

4. Considering the contract performance of the [Buyer] and the [Seller] and the fact that the [Buyer]'s arbitration application was accepted, the [Buyer] should bear the entire arbitration fee.

III. THE AWARD

The Arbitration Tribunal rules that the following claims of the [Buyer] are dismissed:

     (1) The [Buyer]'s claim for price difference of US $138,600;

     (2) The [Buyer]'s claim for the costs of issuing and changing the L/C of US $130.46;

     (3) The [Buyer]'s claim for the cost of local expenses by the Egyptian inspectors of US $40,200;

     (4) The [Buyer]'s claim for the penalty paid to the Military of Egypt; and that

     (5) The [Buyer] shall bear the entire arbitration fee, which was paid by the [Buyer] in advance.

This award is final.


FOOTNOTES

* All translations should be verified by cross-checking against the original text. For purposes of this translation, Claimant of France is referred to as [Buyer] and Respondent of the People's Republic of China is referred to as [Seller]. 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].

** 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.

*** Liming (Anna) Lin, J.D. candidate 2007, Pace University School of Law. She received her MBA from University of Maryland at College Park, and her Bachelor of Science from Nanjing University, China.

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