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CISG CASE PRESENTATION

China 31 December 1996 Fujian High People's Court (Youli v. Gold Star) [translation available]
[Cite as: http://cisgw3.law.pace.edu/cases/961231c1.html]

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

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Case identification

DATE OF DECISIONS: 19961231 (31 December 1996)

JURISDICTION: China

TRIBUNAL: Fujian High People's Court

JUDGE(S): Wei Guangyu, Chenming, Xueqi

CASE NUMBER/DOCKET NUMBER: 166

CASE NAME: Youli v. Gold Star

CASE HISTORY: 1st instance Xiamen Intermediate People's Court Economic Chamber 1995 [CISG applicable; Foreign Economic Contracts Law of the PRC was incorrectly applied]

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

BUYER'S COUNTRY: Hungary (defendant)

GOODS INVOLVED: Silk sport shirts


Classification of issues present

APPLICATION OF CISG: Yes

APPLICABLE CISG PROVISIONS AND ISSUES

Key CISG provisions at issue: Articles 18 ; 53 ; 62 ; 78

Classification of issues using UNCITRAL classification code numbers:

18A3 [Criteria for acceptance: silence or inactivity insufficient];

53A [Buyer's obligation to pay price of goods];

62A [Seller's right to compel payment of price];

78A [Interest on delay in receiving price or any other sum in arrears]

Descriptors: Acceptance of offer ; 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

English: Unilex database <http://www.unilex.info/case.cfm?pid=1&do=case&id=430&step=Abstract>

CITATIONS TO TEXT OF DECISION

Original language (Chinese): [1997] Zhongguo Shenpan Anli Yaolan 371-376; CISG-China Case [HPC/03]: <http://aff.whu.edu.cn/cisgchina/en/news_view.asp?newsid=98>

Translation (English): Text presented below

CITATIONS TO COMMENTS ON DECISION

English: Article 78 and rate of interest: Mazzotta, Endless disagreement among commentators, much less among courts (2004) [citing this case and 275 other court and arbitral rulings]

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Case text (English translation)

Queen Mary Case Translation Programme

Fujian High People's Court (PRC) 31 December 1996

Xiamen Special Economic Zone Youli Business Corporation v. Hungarian
Gold Star International Business Corporation & Wu Danxia
[1]

Translation [*] by Meihua, Xu [**]
Edited by Chi Jiang [***]

[1] Introduction
[2] Claims before the Court of First Instance
[3] Facts and evidence found by the Court of First Instance
[4] Analysis of the Court of First Instance
[5] Judgment of Court of First Instance
[6] Judgment of Fujian High People's Court

[1] Introduction

I. JUDGMENT NUMBERS. First Instance Judgment: Fujian Xiamen [2] Intermediate People's Court [3] (1995) Xia Jing Chu Zi [4] No. 30; Second Instance Judgment: Fujian High People's Court (1996) Min Jing. Zhong Zi [5] No. 166.

II. SUBJECT OF DISPUTE. Contract for sale of silk sports shirts.

III. PARTIES. Plaintiff (Appellee, Defendant of the Counterclaims): Xiamen Special Economic Zone Youli Business Corporation. Legal Representative: Wang Zhongsheng, General Manager. Commissioned Representative: Zhao Xiaobing, Manager of Xiamen Special Economic Zone Youli Business Corporation. Attorney: Wu Xizhong, Xiamen Fangzheng Law Firm. Defendant (Appellant, Plaintiff of Counterclaims): Hungarian Gold Star International Business Corporation. Legal Representative: Wu Danxia. Commissioned Representative: Xu Qionglin, Lawyer of Xiamen Zili Law Firm. Defendant: Wu Danxia, Female, born in 1958, Chinese citizenship (address: 1135 Budapest, XIII Ker Frangepau U. 50-60). Attorney: Xu Qionglin, Xiamen Zili Law Firm.

IV. CASE HISTORY: Second Instance (Appellate Court). V. COURTS AND JUDGES. First Instance: Fujian Xiamen Intermediate People's Court. Panel Members: Chief Justice Huang Jinzhi; Judge Zhou Hongyan; Assistant Judge He Peiming. Second Instance: Fujian High People's Court. Panel Members: Chief Justice, Wei Guangyu; Judge, Chenming; Assistant Judge: Xueqi. VI. DATE OF JUDGMENTS. First Instance: 24 April 1996; Second Instance: 31 December 1996.

[2] Claims before the Court of First Instance

I. Plaintiff [Seller], Xiamen Special Economic Zone Youli Business Corporation, asserted that it signed a Confirmation of Sales Contract (the "Sales Contract") with the Defendant [Buyer], Hungarian Gold Star International Business Corporation, under which [Seller] agreed to sell and [Buyer] agreed to purchase various types of "Meiren" brand silk sports shirts for a total purchase price of U.S. $102,600. [Seller] also signed a pledge agreement (the "Pledge Agreement") with Ms. Wu Danxia whereby Wu Danxia agreed to pledge as collateral for the Sales Contract her bank account (with a balance of U.S. $100,000) at Bank of China Longyan Branch, and further agreed that if [Seller] did not receive the payment document within sixty days after the shipment, [Seller] had the right to withdraw the savings from that bank account to the extent of the unpaid sales price due. After [Seller] shipped the goods, however, [Buyer] did not pay the purchase price as specified in the contract.

[Seller] demanded that [Buyer]:

  1. Pay the purchase price in the amount of U.S. $102,600;
  2. Compensate [Seller] for the delay in payment by paying U.S. $2,265.17 (at an interest rate of 1.1%, and calculated through November 10, 1994);
  3. Bear the loss in the amount of U.S. $3,078 caused by change in foreign exchange rate, which was caused by the delay of the payment; and
  4. Bear all court related costs.

During the hearing, [Seller] modified its second demand to "calculate the interest through the date of the payment."

II. [Buyer] argued that along with the Sales Contract, it also sent a fax to Song [sic] Xiaohui asking her to request the [Seller] to ship the goods via "MAERAK" or "SEALAN", two carriers with a good reputation. Zhu Xiaohui confirmed through telephone that [Seller] had arranged for one of the requested carriers to ship the goods. However, it was not until [Buyer] received the delivery documents that [Buyer] found out that the goods had been delivered by a third carrier. Because of this unauthorized change, [Buyer] not only missed the deadline for delivering the goods to its customers and but also missed the summer sales season.

[Buyer] further stated that due to these problems the two parties exchanged faxes to modify the contract to the effect that [Buyer] would first accept the goods, and that the parties would further negotiate a reduction in the price. However, no agreement was reached concerning the timing for payment of adjusted purchase price. As such, [Buyer] argued that it should not be obliged to pay the price under the Sales Contract. In addition, according to an examination conducted by the Loss Insurance Claim Actuaries Association under the Hungarian Chamber of Commerce, almost 60% of the delivered goods were defective. [Buyer], therefore, counterclaimed and alleged:

  1. [Seller] violated the Sales Contract by failing to choose the carrier and route specified by [Buyer]. As a result, [Buyer] failed to deliver the goods to its customers, and missed the sales season for this merchandise. Moreover, because the goods had serious defects, [Seller] should recall the goods.
  2. Almost 50% of the goods in the second delivery had serious quality problems. [Buyer] would accept the defective goods provided that the [Seller] return U.S. $28,350 of the U.S. $106,380, which had already been paid.
  3. [Seller] unilaterally withdrew from its negotiations with the Buyer regarding the disputed two containers of goods without giving any instruction as to how to dispose of these goods, which [Buyer] had stored in a warehouse. [Seller] should pay the warehouse rental fee.
  4. [Seller] should bear court filing fees for the counterclaim.

After a hearing on 15 April 1996, [Buyer] asked to withdraw its second claim, which was filed in a separate lawsuit. It also changed the warehouse rental fee to U.S. $12,115.93. During the hearing, [Buyer] requested the court to add Zhu Xiaohui as a third party to the litigation on the grounds that she acted as a representative for both the Defendant [Buyer] and the Plaintiff [Seller], and that as such she had significant bearings on the outcome of the case.

III. Wu Danxia asserted that because under the Sales Contract, for which her account had been pledged as a collateral, the condition for payment had not be been satisfied and the parties thereunder had failed to reach an agreement through negotiation, [Seller] should not exercise its right under the pledge agreement against her. Accordingly, she should not be listed as joint-defendant, and her account should not be frozen.

IV. [Seller], the defendant under the counterclaims made by [Buyer], asserted that [Buyer]'s counterclaims were groundless. There was no date for delivery specified under the Sales Contract, nor was there any agreement between the parties for changing or setting forth a new date for delivery. As such, [Buyer]'s allegation that "the goods were not delivered by the date determined in the contract" was groundless. The two parties had agreed that the determination of quality of the goods should be made based on two samples that [Seller] had kept as quality inspection samples. Furthermore, [Buyer] had commissioned Zhu Xiaohui to handle all the quality inspection related issues, and the goods had been inspected by qualified inspection agency under Chinese law. Moreover, nothing in the Sales Contract gave [Buyer] the right to re-examine the goods upon the receipt of such goods. In light of the above facts, [Buyer]'s counterclaims therefore should be dismissed.

[3] Facts and evidence found by the Court of First Instance

The Fujian Xiamen Intermediate Court found that on 26 April 1994, [Seller] and [Buyer] signed a Sales Contract, under which [Seller] agreed to provide 21,600 silk sports shirts of different sizes to [Buyer], at U.S. $4.75/per shirt CIF Budapest, with a total purchase price of U.S. $102,600. The shipping route was from Xiamen to Budapest, and transfer of carriers was allowed. They also agreed that the date for delivery would be decided later, and that [Buyer] shall make full payment to [Seller] by wire transfer within sixty days of shipment. This contract also provided that the quality and quantity of goods shall be based on the documents provided by [Seller], and the quality inspection shall be conducted on the basis of the two sample shirts that [Seller] had kept for such purpose. It also provided that the Pledge Agreement shall be an indispensable part of the Sales Contract, and the Sales Contract shall not come into effect until and unless all the necessary procedures and/or conditions for setting forth the pledge interest have been satisfied.

On 25 April 1994, [Seller] and Wu Danxia signed a pledge agreement, under which the purchase price of the shirts sold by [Seller] to [Buyer] shall be paid after the receipt of goods by [Buyer]. Wu Danxia pledged her bank account (with a balance of U.S. $100,000) at Bank of China Longyan Branch for the benefit of [Seller]. [Buyer] agreed that it would pay [Seller] within sixty days of shipment. If [Seller] had not received by fax the confirmation of wire transfer by payor bank within sixty days of shipment, [Seller] had the right to withdraw the balance from the pledged account.

The Court of First Instance also found that after signing the Sales Contract and the Pledge Agreement, Wu Danxia, the legal representative of [Buyer], sent several faxes to Zhu Xiaohui who had introduced [Seller] to [Buyer]. In the fax sent on 27 April, she asked Zhu Xiahui to make sure that the quality of goods meet the standard. In another fax dated 23 May, Wu Danxia indicated that she expected [Seller] to deliver the goods by 20 June; otherwise [Buyer] would miss the sales season. [Buyer] also asked Zhu Xiaohui to contact [Seller] and inform them the date for the delivery of the goods. On 29 June, [Buyer] sent another fax to [Seller] requesting the latter to make arrangements for the shipment, and specified "MAERSK" as the carrier. On the same day, Zhu Xiaohui sent a fax to Wu Danxia informing her that the Meiren silk sports shirts had not passed the inspection yet and in order to pass the inspection faster, Wu Danxia should draft a general power of attorney authorizing Zhu Xiahui to represent [Buyer] in all activities [in China] in connection with the purchase of the Meiren silk shirts. On the same date, [Buyer] issued the power of attorney as requested and faxed it to Zhu Xiaohui. Then Zhu Xiaohui, as the representative of [Buyer], wrote a confirmation letter to Xiamen Commodity Inspection Agency, which letter stated that the shirts had already been examined by [Buyer], and requested permission for export. As a result, the shirts passed inspection based on "[Buyer]'s consent".

The shirts were loaded onto the ship on 9 July. The day before the departure, Zhu Xiaohui sent a fax to Wu Danxia informing her that the bill of lading and the receipt had already been sent out by express mail. On 13 September, the shirts still had not arrived in Budapest. [Buyer] sent a fax to [Seller] and stated that since winter was coming to Eastern Europe, and shirts had already missed the season, [Buyer] would not pay the price due on 10 September as stated in the Sales Contract. The fax also stated that if [Seller] could find another purchaser, [Buyer] would transfer the goods to that purchaser without condition. Otherwise, [Buyer] could return the goods to [Seller] and wait for the next spring season to reorder, or alternatively it could try to sell the shirt at significantly reduced price.

[Seller], however, only agreed to reduce the price by U.S$0.50/per shirt, and to postpone the payment until 10 November. The two parties failed to reach an agreement on these issues. After the goods arrived in Budapest on 24 October, [Buyer] raised objections with regard to the quality of the goods. [Buyer] refused to make payment to [Seller], and [Seller] brought a lawsuit to this court. [Buyer] counterclaimed.

The above findings are evidenced by the following documents:

     -      The Sales Contract, which was signed by both parties;
     -      The Pledge Agreement, which was signed by [Seller] and Wu Danxia;
     -      Faxes exchanged between the two parties and the faxes between Wu Danxia and Zhu Xiaohui;
     -      The power of attorney issued by [Buyer], as well as the quality confirmation letter and Request for Customs Clearance for Export Products submitted by Zhu Xiaohui to the Commodity Inspection Agency.

[4] Analysis of the Court of First Instance

The Court of First Instance held that the Sales Contract signed by the two parties reflected their true intentions. Its content and form were legal and effective. The two companies agreed in the Sales Contract to a CIF term without specifying the carrier or route. Accordingly, [Buyer] shall not have right to require a particular carrier without [Seller]'s consent. After signing the contract, [Buyer] asked [Seller] to use the MAERSK carrier, but [Seller] did not agree to this. As such, [Buyer]'s request shall not be deemed as an amendment to the Sales Contract. [Buyer]'s claim that the delay of the goods was caused by [Seller]'s breach of the contract by failing to use the suggested carrier was not a valid argument.

The Court of First Instance found that Zhu Xiaohui brokered this business, and also acted as the representative of [Buyer] to examine the goods. From a legal point of view, the outcome of this case does not have a direct bearing on her interest. Therefore, the demand to add Zhu Xiaohui as a third party to the lawsuit should be rejected.

The Court of First Instance also held that the goods had already been examined by the Xiamen Commodity Inspection Agency by virtue of [Buyer]'s consent confirmed by Zhu Xiaohui in her capacity as [Buyer]'s representative. And there was no agreement between the parties that [Buyer] had the legal right to re-examine the goods after the goods arrived at the destination. Therefore, [Buyer] had no right to question the quality of the goods, and [Buyer]'s counterclaim for returning of the goods and reimbursement of the warehouse rental fee should not be accepted.

[Seller] delivered the goods in accordance with the terms of the Sales Contract. However, [Buyer] failed to make payment stipulated under this contract. Therefore, [Seller] shall be entitled to the purchase price plus interest calculated on basis of days of delay. After the goods arrived in Budapest, [Buyer] asked [Seller] to reduce the price because the shipment had missed the sales season. [Seller] agreed to reduce the price $0.50/per shirt and to postpone the payment for two months. This should be considered as a modification by the parties with respect to the purchase price and the date for the payment, and they shall be bound by this modification. Since the payment was designated in US dollars, the demand that the [Buyer] bear the loss caused by exchange rate fluctuation was not reasonable and shall be denied. The pledge reflected the true intent of Wu Danxia; therefore, when no payment was received as provided under the Sales Contract, she shall be jointly liable to [Seller] to the extent of the balance in the pledged account in the amount of U.S. $100,000.

[5] The Judgment of the Court of First Instance

According to Article 16 and Article 23 of the Foreign Economic Contract Law of the PRC [6], the Court of First Instance concluded that:

  1. [Buyer] shall pay [Seller] U.S. $91,800 together with interest (at the rate of the current People's Bank of China's US dollar loan rate, and calculated from 10 November, 1994 to the day of its payment) within ten days of the effectiveness of the judgment.
  2. Wu Danxia shall be jointly liable for the above amount to the extent of the balance in her account at Bank of China Longyan Branch in the amount of U.S. $100,000.
  3. [Seller]'s other claims shall be dismissed.
  4. [Buyer]'s counterclaims shall be dismissed.

The filing fee of this court is RMB 13,829 [7]. [Buyer] and Wu Danxia shall be jointly responsible for RMB 12,446, and [Seller] shall be responsible for RMB 1,383. The filing fees of the counterclaim shall be borne by [Buyer].

[6] The Judgment of the Court of Second Instance

     1. Appellant [Buyer]'s claim

[Buyer] asserted that:

          (1) This dispute is between Chinese and Hungarian parties. Since there is no governing law provision under the Sales Contract, the CISG, which was ratified by both parties' States, should be applied. The Court of First Instance's application of the Foreign Economic Contracts Law of the PRC was erroneous.

          (2) Just because [Buyer] told Zhu Xiaohui several times to examine the goods closely does not mean that she was given the right to make a determination as to the quality of the goods. Therefore, the determination as to whether the quality of the goods meets the quality of the sample still remained with [Buyer]. The power of attorney was only issued for the purpose of customs clearance. Therefore, the Court of the First Instance should not, based on such fact alone, have determined that Zhu Xiaohui was the representative of [Buyer] with the right to examine and accept the goods.

          (3) The Court should have taken into account the faxes, phone calls, and memorandum between the two parties before and after the contract was formed.

          (4) On 29 June, the [Buyer] sent a fax to [Seller] to ask it to choose "MAERSK" as its carrier. The lack of written objection from [Seller] should be deemed as consent. Therefore, [Seller] shall be liable for the breach of the contract, because of its delay of the delivery.

          (5) There was no provision in the Sales Contract with respect to the inspection of the goods. Therefore, either [Seller] or [Buyer] was entitled to appoint an appropriate agency to examine the goods against the sample goods before loading or after receiving the goods respectively. The Loss Insurance Claim Actuaries Association under the Hungarian Chamber of Commerce was a legally established agency, and its report had been confirmed as a true copy by the Hungarian Embassy. Such report therefore should be admitted as evidence in this case. The fax sent on 6 October 1994 by [Seller] to [Buyer] evidenced that the contract was terminated.

Therefore, the Court of First Instance not only had made serious erroneous factual findings but also had applied the wrong governing law. [Buyer] petitioned the Court of Second Instance to reverse the ruling of the Court of First Instance and order [Seller] to recall the goods and to bear the warehouse rental fee in the amount of U.S. $12,115.93. [Buyer] also petitioned the Court of Second Instance to unfreeze Wu Danxia's U.S. $120,000 [sic] savings account and demand [Seller] bear all the filing fees.

     2. Appellee [Seller]'s position

[Seller] asserted that:

          (1) Since the two parties did not decide on the governing law, the Court of First Instance was correct in applying the Foreign Economic Contracts Law of the PRC in light of the "most-direct-contact" principle.

          (2) Zhu Xiaohui clearly had acted as a representative for the [Buyer].

          (3) The rights and obligations of the parties shall be determined by the Sales Contract. The phone calls and faxes were just the reflection of the mind of one party, which shall not be considered as part of the Sales Contract.

          (4) Under a CIF term, in the absence of consent by [Seller] or a provision in the Sales Contract, [Buyer] cannot insist on the use of "MAERSK" as carrier. The finding of the Court of First Instance was correct, and the law applied was correct. This court should dismiss [Buyer]'s appeal.

(There was no written brief from Wu Danxia)

     3. The findings of the Court of Second Instance and the evidence

The Fujian High Court found that the findings of the Court of First Instance were correct. The Court also recognized that [Buyer] had submitted to the Court of First Instance the report prepared by the Loss Insurance Claim Actuaries Association under the Hungarian Chamber of Commerce, which report indicates that almost 60% of the shirts were not defective.

     4. Reasoning

The Court of Second Instance reasoned that the decision made by the Court of First Instance that the Sales Contract by the two parties was legally effective is correct. Since, under the CISG term, there was no agreement regarding the carrier or the shipping route, [Seller] should bear the risk up to the time when the goods cross the ship's rail. After [Seller] shipped the goods under the contract, it should not bear the risk of delay caused by the carrier. Since [Buyer]'s fax to [Seller] on 29 June requesting [Seller] to choose "MAERSK" as the carrier was not agreed upon by [Seller], [Buyer]'s claim that [Seller] breached the contract and was liable for the delay of the delivery due to choosing the wrong carrier is not acceptable.

The Court of Second Instance also reasons that Zhu Xiaohui had acted in two different capacities, one as the broker that introduced the business, and the other as the representative of [Buyer] entrusted to examine the goods. Before the goods were shipped, Zhu Xaiohui confirmed the quality of the goods as a representative of [Buyer]. Relying on such confirmation, Xiamen Commodity Inspection Agency confirmed the quality of goods involved. [Buyer]'s objection to the quality of the goods based on the report from the Loss Insurance Claim Actuaries Association under the Hungarian Chamber of Commerce is not acceptable.

Both before and after the goods arrived in Budapest, the two parties discussed via fax how to deal with the goods. Even though no agreement was reached, [Seller] and [Buyer] still had a contractual relationship.

The Sales Contact signed by the two parties was an international sales contract. Because no governing law was specified in the contract, the CISG should automatically be applied. The Court of First Instance's application of the Foreign Economic Contracts Law of the PRC was erroneous.

     5. Holding of the Court of Second Instance

According to Article 1(1)(a), Article 53, Article 62, Article 78 of CISG and Article 153 (1)(i) of the Civil Procedure Law of the People's Republic of China, the Court ruled that:

  1. The appeal is dismissed. The Court of First Instance's judgment is affirmed.
  2. [Buyer] shall bear the filing fee for appeal in the amount of RMB 28,359
  3. The filing fee of the Court of First Instance shall be paid according to the judgment of the Court of First Instance.


FOOTNOTES

* All translations should be verified by cross-checking against the original text. For purpose of this translation, Plaintiff-Appellee of People's Republic of China is referred to as [Seller]; Defendant-Appellant of Hungary is referred to as [Buyer].

** Meihua Xu is an LL.M. candidate at the 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.

*** JIANG Chi is with the New York office of Debevoise & Plimpton LL.P.

1. [1997] Zhongguo shenpan anli yaolan, pp. 371-376. All footnotes herein are by the translator.

2. Fujian is one of the provinces in South China, and Xiamen is a city located in Fujian province.

3. "China has a four-level court system. The Supreme People's Court sits in Beijing; the High People's Courts sit in the provinces, autonomous regions and special municipalities. Intermediate People's Courts sit at the prefecture level and also in parts of provinces, autonomous regions, and special municipalities. There are also basic People's Courts in counties, towns, and municipal districts.

The High People's Court holds preliminary hearings for major civil and criminal cases of a province, an autonomous region or municipality directly under the Central Government. It also conducts retrials or second trials when the people's procuratorate disputes the judgment or the defendant appeals against the verdict or ruling by the Intermediate People's Court at the first trial level. The Intermediate People's Court hears of counterrevolutionary crimes and cases involving life imprisonment and the death penalty, as well as actions against foreigners or Chinese who infringe upon the legitimate rights and interests of foreigners. It handles civil and criminal cases in an appellate capacity when the people's procuratorate disputes the judgment or the defendant appeals against the verdict or ruling delivered by the people's court at the trial level." See Du Xichuan and Zhang Lingyuan, CHINA'S LEGAL SYSTEM, pp. 91-92.

4. Xiamen Intermediate People's Court, Economic Chamber, First Instance.

5. Fujian High People's Court, Economic Chamber, Second Instance.

6. "The Foreign Economic Contract Law of the People's Republic of China (Foreign Economic Contract Law) has been in existence since 1985. This law applies to contracts with foreign elements except certain transportation contracts. For example, a joint venture contract between a Chinese party and a foreign party is a contract with foreign elements and, therefore, is subject to the jurisdiction of the Foreign Economic Contract Law. For another example, a technology transfer contract between a Chinese company and a foreign company involves foreign elements. The Foreign Economic Contract Law will apply. A contract may change its nature and applicable law by adding or deleting a party to the contract. This change can be used as a technique for parties, especially foreign parties, to choose the desirable Chinese Contract Law. For example, if the parties to the contract want to subject their contract to the Foreign Economic Contract Law, they may add a foreign company to the contract in a suitable role." See Kenneth A. Cutshaw Jun He Law Offices, DOING BUSINESS IN CHINA, (Second edition) pp. 4.010-4.011.

7. The currency of the People's Republic of China (Renminbi) indicated as [RMB].

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Pace Law School Institute of International Commercial Law - Last updated May 11, 2010
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