I said you introduced a like a three tier systems that leads to architecture.

So first I think you

negotiations. Yes. And of course we face them mediation and understand I restrictions, but

they remember you specified time frames, so like the negotiations for like 15 or 50 days, 15

days, yeah, that's good because. Can go on forever. And some people specialize. Yeah. Second

rounds of round. Yeah. Yeah, Yeah, exactly, exactly. So it's good that you interviewed this

time frame in order to prevent, you know, some party from using this phase negotiation.

Good space to prolong the dispute. Yeah, I feel like, OK, two points. So the seat of mediation

and more importantly of arbitration is impacts. So we have a French company in the Chinese

company and you specifically decide to designate the Super dictation as impairs. I would say

that this in you know. The balance is moved in favor of the French part. You know, if the

French parties based in Paris or in any other French city, it's much less expensive to travel to

Paris. You know, maybe say maybe they're even next door to ICC, so. Very convenient. And

the Chinese party would need to book tickets and to fly from China to Paris, which we apply

the Chinese law. Yeah, that's the second point. You said the second point. So you decided to

sort of describe the balance between? Comparison by the government employees and slow.

Well, I would say that I. Choice would be both would be designated the City of Arbitration

and to choose the government was that would be interested in both parties. So let's say

administration in London and English was certainly the company in law. It's equally

inconvenient for both parties because france and china are civil law countries so english

flourish is common law is more or less unfamiliar for both of them or you know you can just

point some geographical space between child young from both parties not in china not in

france she

OK, good. Where we should look for the interest rate, So I would say that the common law

should be. Singapore. Or have a. What do you? Choose the Asian world. Yeah, but that's the

issue. Of course, like the valid. For those legal vacuum at that point. And then we use. Yeah,

but. Pakistan also i it is less expensive to highlight just one person one person instead of

three but three is a popular choice especially the disputes might be very complicated of

course it's better to have three people on the team instead of answering stop yeah it's good

it's going to work. So we can have a binding version based on this. Well, first of all I would
say that this provision on this three versions, the language versions of the contract. Should

not be really appear in their close. So personally, do not really not specify which language

this is. It should be said that contract should be done in three versions and in case of any

conflict the English one should prevail, right? But what to other versions like you should say

are done? OK, well you should rewrite it. OK, so how would you usually do that in practice?

To say is that this contract is done in English, French and Chinese in case of any conflicts that

people use what you wrote. In case of any conflict, the English version should be really

should be. You suggested that you show one, but I would say that this provision does not

belong to arbitration clause. OK. These quite long there are other in this place, of course, but

it's not usually done like set. It's interesting that you specify specify the method of choosing

arbitrators. So one party designates one, the other party designates another one, and the

Singapore Arbitration Institution chooses the third one. Uh, you can do that. And yeah, it's

it's certainly valid. But in danger is that there might be conflict between this method, which

is an arbitrary arbitrators and the method set forth in this Arbitration rules of Singapore.

Center for arbitration, so you could check those rules. OK, so you should have done so. I do

not know those tools either, but let's say that those rules specify said arbitrate. All

arbitrators should be appointed by this arbitration institution or how it's usually done in

practice. One part SharePoint. And they served on the appointed by the institution, but it is

decided by those who are retracted. So let's say we have this viewpoint, one arbitrator I

appoint upon arbitrator and those arbitrators negotiate who will be the service someone

who's they both trust and we do not influence their decision. So let's say that you have this

message that. It's OK. You can do that in your arbitration clause and in different methods.

You served in the rules on arbitration that you specifically referred to. So they say conflict.

What do you mean this case? I'm not sure what you doing this case. Probably the admission

institution would OK. It can be flexible. It can agree on this message that you chose or it can

be really rigid and refused to me seriously speed because you do not comply with their rules.

So that's that's the danger you can. You can do that, but you should check that the same. This

method is or is not specified in the rules of the institutional support. But otherwise, yes,

there otherwise dictators. Yeah. Otherwise it's it's good, you can you can work with them all
right. Any follow-ups on this clause? OK, so and the last group, please present your clothes.

Oh, our our clothes are tender like the group too. Singapore and it's our single close that. And

then discharge or whatever they show arising out of or in connection with this contract,

including any question regarding its existence. And the termination shall be referred and

finally resolved by the arbitration in Singapore in accordance with the Attraction Rules of

the Singapore International Arbitration Center. And the both parties are agreed that the

applicable law for this country is is true, OK. That's it, right. Yeah. OK. So I think this is the

the shortest one. So you did not specify the language for arbitration, right? Language. Defied

I guess English English right? Right This one as well. You guys did not choose on which

formation right in the in the post. Sorry. You well, you talked about distributions of the

contract and the English version should prevail, but you did not choose the language for

arbitration proceedings, right? Yes, we do. OK. You choose English, right? Yeah, Sorry, I just

missed that. Yeah. So OK, so if that group chose language, you are the only ones that did not

choose the language for arbitration. You don't have to. It can be decided on later. But yeah,

the task is formulated. Is that? Those companies are negotiating conflict with your preparing

the arbitration clause for them, and probably it would make sense to choose a language that

would be neutral to both parties. English is the popular choice, both French and Chinese.

Yeah, you don't have to, but it would be nice addition to say that there should be done in

English or any other language. German. Singapore, Yeah, the same issue with the CSG. There

might be situations they're not covered by the CHP and the other, you know, shell decide

itself which law governs contract dispute, not not. Sorry so. It would be. Better to choose

some national law, English law, U.S. law, German law if you want. Yeah. But that's why I see

there is a clear intention to submit all these pieces of arbitration, which was not to conduct

any mediation or negotiations or conciliation. It's it's not refined here. In practice, it may just

prolong the resolution of the dispute. So it's OK. Yeah, it's it's functional. Yeah, so. That's they

said before, there are model clauses available on the arbitration institution websites that you

can use. So yeah, the single arbitration may be decided in the arbitration clause, the language

of arbitration, as we just talked about the rules, the governing law of the merits of the case.

Can be decided. You can decide on how many arbitrators you want and the. Yeah, that's
that's probably it. So I would say that the first group is really on the maximalist end of the

spectrum. You specify quite a lot of. Issues pertaining to arbitration and you are on the

minimalist end of the spectrum. You're closest, quite small. It doesn't make it bad as, as I told

them, I'm going to tell you again. The main thing about the cost is a clear intention to make

all disputes arising. Out of the contract. To make to to submit itself to arbitration arbitration.

And I yeah, I think all of you opposes do this job. OK. So there are only, yeah, 13 minutes left.

There is a case that I wanted to talk to you about the Chinese case, but I think that it's not

doable. That we have to read it and then discuss it. Maybe you can next time. It's this one.

But we are really, really have to talk about medication next time. Well we'll see. We have

questions on. Any sense of today? OK. I was calling today. Thank you for your activation and

arbitration clause drafting and see you tomorrow please. Voice control on this end and you

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Tutorial 2