Trecho do comentário: "If the United States and Great Britain were said to be two countries separated by the same language, France and Great Britain now seem to be two countries separated, not only by the Channel, but by the same case. The 'KFG case', as it is known, is likely to become a major case in international arbitral law, as it focuses on a core issue: the law applicable to the arbitration agreement."

I Decisions -- Introduction -- Factual and procedural background -- Theterms of the FDA -- The judgment below -- The grounds of appealand cross-appeal -- Summary ofthe parties’ submissions -- Analysis and conclusions -- II COMMENTARY -- The English approach: thelex contractus -- The French approach: the "lex arbitri"