Are there multilateral or regional systems determining jurisdiction?
So far, international harmonization of issues of jurisdiction is relatively limited. Various international Conventions dealing with the harmonization of specific areas of law contain provisions on jurisdiction over disputes arising in the specific field. However, as regards jurisdiction and the enforcement of foreign judgements in general, a widely accepted multilateral instrument – which would also cover intellectual property disputes – does not yet exist. Such an instrument, a draft Convention on Jurisdiction and Foreign Judgements in Civil and Commercial Matters, had been proposed at the Hague Conference on Private International Law (Hague Conference), the principal forum for the adoption of international instruments in the area of private international law codification. However, since consensus on the proposed draft Convention could not be reached, it was decided, in 2003, to work on a scaled down version of the Convention, limited to jurisdiction based on party agreement, as well
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