The Choice-of-Law Rules of the European Community Regulation on the Law Applicable to Non-Contractual Obligations: Simple and Predictable, Consequences-Based, or Neither?

The article focuses on the issues regarding the European Community Regulation on the Law Applicable to Non-Contractual Obligations (Rome II), a regulation that aims to draft new choice-of-law rules. Accordingly, Rome II provides foreseeable answers to choice-of-law issues. The exceptions to the regulation's rules create major predictability problems. Rome II also gets high marks for including time limitations and burden of proof within the scope of its rules.