• 제목/요약/키워드: International Comparison

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ICSID중재와 UNCITRAL중재의 중재절차에 관한 비교연구 (A Comparative Study on Certain Procedural Issues of ICSID and UNCITRAL Arbitrations)

  • 서경
    • 무역상무연구
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    • 제43권
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    • pp.481-507
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    • 2009
  • Along with continuous increase in international investments encouraged by wide spread bilateral investment treaties (BIT) including free trade agreements (FTA), international investment disputes have been also increasing. This means that a host State, an importer of foreign investments, and a investor who exports its investment to foreign State, need to take measures to prevent international disputes arising from international investment or to prepare for the arbitration for resolving the disputes. Under these circumstances, this paper compares ICSID arbitration rules and UNCITRAL arbitration rules in respect of (i) the institution of arbitration, (ii) the appointment of arbitrators and the composition of arbitral tribunal, and (iii) the procedures for, and the form of, arbitral awards. On base of this comparison, this paper further suggests certain practical issues that the host State's government and the foreign investors should be aware of in order to be ready for the resolutions of disputes by ICSID or UNCITRAL arbitrations.

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국제전자상거래시대(國際電子商去來時代)를 대비(對備)한 BOLERO Project와 TradeCard System (The Comparison of BOLERO project and TradeCard syetem as Settlement Method in International Trade)

  • 안병수
    • 무역상무연구
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    • 제13권
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    • pp.933-977
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    • 2000
  • BOLERO project and TradeCard System are attracted public attention as new settlement method that is able to substitute for documentary letter of credit. BOLERO is the business processes and methods, together with the digital information system, which are provided by Bolero International for communicating Messages and Documents and facilitating business transactions. TradeCard aim to make international business-to-business e-Commerce easy, fast, inexpensive and secure while innovating current documentary compliance and financial settlement mechanisms. The main purpose of this paper is to search the possibility of paperless trade. Since, this paper examine the international legal feasibility of these systems and compare the strength and weakness.

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Recent changes to the Korean Arbitration Act and its Comparison with Singapore: Korea's Potential to Become an Arbitration Hub

  • Kim, Jae-Hyun;Hopkins, Bryan E.
    • 한국중재학회지:중재연구
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    • 제26권3호
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    • pp.27-50
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    • 2016
  • International arbitration as a dispute resolution mechanism in Asia is growing in popularity. Singapore has long been acknowledged as a regional arbitration center but Korea is now facing an increased demand as an arbitration center as well. As Singapore competes with Hong Kong and other international arbitration centers, and as Korea tries to become an alternative to Singapore, both Singapore and Korea have updated their arbitral laws and arbitration rules to reflect the current international arbitration trends. This paper examines the recent changes in the arbitration laws of Singapore and Korea, with an emphasis on recent changes in Korean arbitration laws that are designed to increase Korea's popularity as a regional arbitration center. Though Korea's reputation as an arbitration center is increasing, it is still not viewed as a major arbitration service provider. It is against this backdrop that Korea's international arbitration laws and rules will be viewed, with suggested changes to increase Korea's reputation as not only a regional hub but a center of international arbitration.

The French approach to enforcement of arbitral awards, international public policy and corruption

  • Samantha Nataf
    • 한국중재학회지:중재연구
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    • 제33권3호
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    • pp.31-68
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    • 2023
  • In recent years, French courts have decided to adopt an uncompromising stance in the fight against corruption in international arbitration. While French enforcement/annulment courts were originally conducting a limited review of arbitral awards dealing with corruption allegations on international public policy grounds, they now carry a full re-examination of such awards accepting that a corruption plea be raised for the first time before them and admitting new evidence. What is at stake, in terms of international public policy, is to define the happy medium between, on the one hand, the necessity to preserve the enforceability of international arbitral awards, and, the necessity to fight corruption. This paper presents the evolution of French case law in the past years and makes a critical assessment of the French approach by comparison with other jurisdictions.

국내·외 스포츠 브래지어 생산실태 (Review of domestic and international sports brassieres)

  • 박자영;장정아
    • 복식문화연구
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    • 제24권3호
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    • pp.287-300
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    • 2016
  • The purpose of this study was to review materials that could provide basic data about sports brassieres. In this study, 486 sports brassieres were collected online from 31 brands between November 2015 and February 2016. First, the comparison of compression and encapsulation in sports brassieres identified many different styles. The characteristics of compression brassieres included a cut cup, the front center height of a full cup, round neckline, short front hem, all in one shoulder strap with a patterned racerback design, all in one closure, no wire, and separation cup styles. The characteristics of encapsulation brassieres included a V-shape neckline, mixed round shoulder strap design, back closure, and all in one cup. Second, the comparison of domestic and international sports brassieres sorted the items differently. The characteristics of domestic products included compression brassieres, non-cut cup, the front center height of a full cup, round neckline, short front hem, an all in one shoulder strap with a patterned round design, all in one closure, no wire, and a separation cup. The characteristics of international products included a cut up, racerback shoulder strap design, and an all in one cup. Third, the analysis of domestic and international sports brassieres sizes found that six options were available for domestic compression sports brassieres and nine sizes were available for international products. Domestic encapsulation sports brassieres offered five under bust sizes and five cup sizes. International products offered eight under bust sizes and sixteen cup sizes.

스마트 의류의 사용환경 내구성 시험에 대한 국제 표준화 현황과 제품의 신뢰성 향상 및 품질 관리를 위한 향후 과제 (Current Status of International Standardization for Durability Test Methods in Smart Clothing and Future Challenges in Enhancing Product Reliability and Quality Control)

  • 김시연;임가영;김수경;이정현
    • 한국의류산업학회지
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    • 제25권3호
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    • pp.398-408
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    • 2023
  • Smart clothing products can experience a decrease in performance and reliability due to various mechanical, biological, and chemical stress factors that occur throughout their life cycle. These issues can hinder consumer acceptance of the products. This study aims to enhance the reliability of smart clothing and facilitate quality control by analyzing and identifying the current status of international standardization for smart clothing and electronic textiles (e-textiles). The focus of this analysis was on the durability test methods in the use environment. Furthermore, similar standards published by different standardization organizations for durability tests were compared in depth. The study showed that a total of 27 international standards have been developed or are currently under development. The current standardization efforts mainly aim to develop functionality and durability test methods for smart clothing and e-textile products. A detailed comparison was made between two international standards (IEC 63023-204-1:2023 and AATCC TM210:2019) specifically in relation to the washing durability test method and the electrical resistance measurement standards (BS EN 16812:2016 vs AATCC EP13-2021), before and after the environmental exposure tests. Based on this comparison, several suggestions have been made and discussed for the future revision of these international standards.

The Genealogical Study on Electronic Bill of Lading

  • LEE, Bong-Soo
    • 무역상무연구
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    • 제69권
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    • pp.349-370
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    • 2016
  • This thesis examines the problems faced in the electronic bill of lading for which improvements are necessary, and suggests various ways of overcoming those problems. First, to build a negotiation system for electronic B/Ls, active participation from related parties in addition to the government support is essential. Second, electronic B/Ls cannot be utilized within a short period of time in current commercial practices. Third, there should be infrastructure which connects all parties of international commerce through an electronic system. Fourth, instead of promoting mutual recognition through international treaty, there should be a plan which legally specifying mutual recognition between certification authorities. Fifth, it is needed to ease the strictness of electronic signature to promote the global negotiation of electronic B/Ls. Lastly, in prima facie weight of evidence, there was a significant difference with the Rotterdam Rules even in comparison with the Commercial Act which was amended with the significantly advanced rules on electronic B/L. He believed there should be a discreet consideration on these matters at the revision of the Commercial Act. For this, the government has to provide support more aggressively with more interest and commitments.

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A Design of Simple and Precision Direction Finder with a Combination of an Amplitude Measurement and Phase Measurement

  • Lim Joong-Soo
    • International Journal of Contents
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    • 제1권2호
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    • pp.35-38
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    • 2005
  • This paper describes a design of simple and precision direction finder that can be adapted to shipboard or mobile vehicles used for Electronic support measure, ELINT and radio signal monitoring systems. The direction finding technology has improved with monolithic integrated circuit, linear array antennas, and interferometer. Interferometer uses the phase-comparison principle and has a good direction finding accuracy but it has an ambiguity problem. We suggest a simple ambiguity solver using phase-comparison technology with amplitude-comparison principle. The direction finding device that has been designed by the suggested method has 0.7 degree RMS error in azimuth angle and 0.6 degree RMS error in elevation angle in 0.5 - 2.0 GHz.

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