Court of Chancery Applies Delaware Law To German Investment
QVT Fund LP v. Eurohypo Capital Funding LLC I, C.A. 5881-VCP (July 8, 2011)
When will Delaware law apply to a dispute is often not an easy question to resolve. That is true even when the parties had agreed to sue under Delaware law but the issue presented may involve foreign law as well. Here the Court sorted through a complicated deal involving the internal affairs of a German bank and held that some of the issues might be governed by German law but the main dispute was subject to Delaware law. This analysis is thus a useful guide in other complicated choice of law situations.
