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Ingmar GB Ltd. v. Eaton Leonard Technologies Inc.

 2000 E.C.R. I-9305 (2000)

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Ingmar GB Ltd. v. Eaton Leonard Technologies Inc.

European Union Court of Justice

 2000 E.C.R. I-9305 (2000)

Facts

Eaton Leonard Technologies, Incorporated (Eaton) (defendant) was a California company that manufactured pipe-bending machines. Ingmar GB Limited (Ingmar) (plaintiff) was a wholesaler established in the United Kingdom. Eaton and Ingmar entered a contract that appointed Ingmar as Eaton’s exclusive agent to sell Eaton’s machines in the United Kingdom. The contract contained a choice-of-law clause, which provided that California law would govern the terms of the contract. However, the European Council had a directive regarding exclusive-agency agreements for commercial transactions, which included Article 17, a mandatory provision of the directive. The contract between Ingmar and Eaton, which constituted an exclusive-agency agreement, was terminated in 1996. Ingmar sued Eaton in the court of justice in England. The English court held that the United Kingdom regulations implementing Article 17 of the European Council’s directive did not apply because the contract was governed by California law. Ingmar appealed to an English court of appeal. The court of appeal sought a preliminary ruling from the European Court of Justice regarding whether a choice-of-law provision in an exclusive-agency agreement that selected California law as the governing law was valid if voluntarily chosen by the parties to the agreement.

Rule of Law

Issue

Holding and Reasoning

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