Professional Documents
Culture Documents
Research Assignment Transnational B2C E-Disputes: Towards a Global B2C ODR System
TABLE OF CONTENT
I. INTRODUCTION......................................................................................3 II. TRANSNATIONAL E-COMMERCE THE CHALLENGES.................................4 III. THE ADR EXPERIENCE...........................................................................7 IV. ODR WHAT IS ALL THE HYPE ABOUT?..................................................8 V. ODR RECENT TRENDS AND INITIATIVES AROUND THE WORLD..............10 VI. LEGAL OBSTACLES CAN ODR DELIVER THE GOODS?........................12 A. FUNDING.................................................................................................................12 B. ENFORCEMENT...........................................................................................................15 VII. CO-REGULATION A COMPLEMENTING STRATEGY...............................19 VIII. A GLOBAL B2C ODR SYSTEM PUTTING THE PIECES TOGETHER...........20 IX. CONCLUDING REMARKS THE FUTURE IS NOW.....................................21 X. BIBLIOGRAPHY....................................................................................23 BOOKS........................................................................................................................23 ARTICLES AND JOURNALS....................................................................................................23 OTHERS......................................................................................................................26
I.
Introduction
In the context of transnational e-commerce dispute resolution, conventional legal solutions based
on localization and territoriality are clearly inappropriate for the purposes of determining issues of jurisdiction, given the borderlessness1 of the Internet. Traditional avenues for redress are also impractical from a cost-benefit point of view. Various solutions to resolve these issues have been proffered in the literature pertaining to this area, such as modifying existing laws 2, introducing regulated online complaint/feedback forms on the businesss website3 and utilizing new technologies4. However, the instantaneous, ubiquitous and delocalised transnational e-commerce necessitates solutions with similar qualities, and it will be argued that online dispute resolution (ODR) can mirror the success of conventional alternate dispute resolution (ADR) employed in the context of international business transactions to form the bedrock of an inexpensive, expeditious and efficient global dispute resolution system for transnational e-commerce. The discussion will be confined to business-to-consumer (B2C) transactions, where the difficulties are the most pronounced. For such a system to be workable, however, several attendant legal issues such as funding and enforceability will need to be resolved. Also, a project on a global scale as such will require harmony of legal rules on an international level, as well as an accreditation scheme to ensure the quality of the ODR providers under this system. International cooperation is therefore paramount. In light of the recent spate of activity, it appears that such a project, whether or not in the mould of the model suggested by the author herein, is not merely a pipe dream, but indeed a real possibility. In light of the foregoing, part II will sketch the recurring legal challenges that transnational ecommerce face. Part III will visit the offline success of ADR in the context of international business. Part
1
Dan Jerker B. Svantesson, Geo-location Technologies and Other Means of Placing Borders on the Borderless Internet (2004) Law papers. Paper 63. <http://epublications.bond.edu.au/law_pubs/63> 2 Faye Fangfei Wang, Obstacles and Solutions to Internet Jurisdiction A Comparative Analysis of the EU and US laws (2008) 3(4) J. of Intl. Comm. Law & Tech. 233241. 3 Zheng Teng, An Effective Dispute Resolution System for Electronic Consumer Contracts (2007) 23(1) Computer Law & Security Report 4252. 4 Supra Note 1.
Trends in Online Shopping Report: a global Nielsen consumer report (February 2008), available at: http://nz.nielsen.com/news/OnlineShopping.shtml. 6 WhosOn, ATG Research Report European Consumer Views of e-Commerce Buying Behaviour and Trends (September 2009), available at: http://www.atg.com/resource-library/white-papers/ATG-euro-commerce-consumersurvey.pdf. 7 World Internet usage has grown a staggering 444.8% since the turn of the millennium (Source: Internet World Stats Internet Usage Statistics (2010), available at http://www.internetworldstats.com/stats.htm. 8 Colin Rule, et al., Designing a Global Consumer Online Dispute Resolution (ODR) System for Cross-Border Small Value-High Volume Claims OAS Developments, (2010) 42 Uniform Commercial Code Law Journal 221 255.
OECD Conference on Empowering E-consumers: Strengthening Consumer Protection in the Internet Economy, Background Report (8-10 December 2009) at 36, available at: http://www.oecd.org/dataoecd/44/13/44047583.pdf (Consumers should be provided meaningful access to fair and timely alternative dispute resolution and redress without undue cost or burden.); See also A/CN.9/706 Note by the Secretariat Accompanying the United Nations Commission on International Trade Law, 43rd Session, Possible future work on online dispute resolution in crossborder electronic commerce transactions (New York, 21 June 9 July, 2010) 50, available at: http://daccess-ddsny.un.org/doc/UNDOC/GEN/V10/531/00/PDF/V1053100.pdf?OpenElement. 10 Fred Galves, Virtual Justice as Reality: Making the Resolution of E-Commerce Disputes More Convenient, Legitimate, Efficient, and Secure (2009) Journal of Law, Technology & Policy 162 at 4 (noting that the average online transaction is about US$150.00). 11 Kauffman-Kohler and Schultz, Online Dispute Resolution: Challenges for Contemporary Justice (2004: The Hague: Kluwer Law International). 12 Ian Lloyd, Information Technology Law, 5th ed., (2008: Oxford, Oxford University Press) 1.18 (may theoretically be subject to the jurisdiction of virtually all of the world's legal systems). 13 See, for e.g., Yahoo! Inc. v. LICRA (T.G.I. Paris, May 22, 2000, Interim Court Order No. 00/05308, 00/05309), where French law was applied due to Yahoo's auction site being accessible in France. 14 Chris Reed, Internet Law, 2nd ed., (2004: Cambridge, Cambridge University Press) 7.1.3; See also Inset Sys., Inc. v. Instruction Set, Inc., 937 F. Supp. 161, 164165 (D. Conn. 1996) (holding that the Connecticut court could exercise personal jurisdiction over the Massachusetts defendant because he maintained a Web site with advertisements and a toll-free phone number that was accessible by any person in any state, and therefore the defendant purposefully availed himself of the privilege of doing business not only with the forum state, Connecticut, but with any state in the United States of America); See, further, the obiter dicta in Decker v. Circus Circus Hotel, 49
F. Supp. 2d 743, 745 (D.N.J. 1999). 15 For e.g., within the European Union, the Brussels I Regulation simplified the jurisdictional rules pertaining to econsumer contracts; At the international level, the Hague Conference on Private International Law produced a draft convention on jurisdiction and foreign judgments in civil and commercial matters, although disagreement over the rules that should apply to the Internet and e-commerce resulted in negotiations to be halted in 2001 and its eventual culmination in the form of a very limited Convention on Choice of Court Agreements, concluded on June 30, 2005. 16 Article 16 of the Brussels I Regulation empowers consumers to sue on contracts completed over the Internet in the courts of their country of domicile, and further provides that a consumer can only be sued in his country of domicile. 17 See, e.g. the pioneering articles of David Johnson and David Post, Law and Borders The Rise of Law in Cyberspace, (1996) 48 Stanford Law Review 1367--1402; Catherine Kessedjian and Sandrine Cahn, Dispute Resolution On-line, (1998) 32(4) The International Lawyer 977990; Veijo Heiskanen, Dispute Resolution in International Electronic Commerce, (1999) 16(3) Journal of International Arbitration 2944; Janice Nadler, Electronically-Mediated Dispute Resolution and E-Commerce (2001) 17(4) Negotiation Journal 333347; Julia Hrnle, Online Dispute Resolution in Business to Consumer E-commerce Transactions, (2002) Journal of Information, Law and Technology (2), available at: http://www2.warwick.ac.uk/fac/soc/law/elj/jilt/2002_2/hornle/; Jagruti Chauhan, Online Dispute Resolution Systems: Exploring E-Commerce and E-Securities (2003) 15(99) Windsor Review of Legal and Social Issues 99112; Ivonnely Coln-Fung, Protecting the New Face of Entrepreneurship: Online Appropriate Dispute Resolution and International Consumer-to-Consumer Online, (2007) 12 Fordham Journal of Corporate & Financial Law 233258. Lilian Edwards and Caroline Wilson, On-line Dispute Resolution in Cross-border Consumer E-commerce Transactions: Lessons From eBay and ICANN, (2007) 21(3) International Review of Law, Computers & Technology 315333; Supra Note 10; Supra Note 8.
See section V below. Edwards and Wilson, Supra Note 17 at 318. 20 See Ethan Katsh and Janet Rifkin, Online Dispute Resolution: Resolving Conflicts in Cyberspace (2001: California, Wiley); see also Colin Rule, Online Dispute Resolution for Business: B2B, E-Commerce, Consumer, Employment, Insurance and Other Commercial Conflicts (2002: California, Jossey-Bass). 21 ADR can be private or court-annexed. Most commonly used ADR methods include negotiation, mediation or conciliation, neutral listener agreement, mini-trial and summary jury trial, med/arb, expert determination, contractual adjudication, executive appraisal, rent-a-judge or private judging, last-offer or pendulum or baseball arbitration. 22 See Henry Brown and Arthur Marriott, ADR Principles and Practice, 2nd ed. (1999: London, Sweet & Maxwell) at 4-084 for an extensive use of ADR and arbitration in the context of international business. 23 Ibid at 2-002. See also, Alan Redfern and Martin Hunter, Law and Practice of International Commercial Arbitration, 4th ed. (2004: London, Sweet & Maxwell) at 1-52. 24 See, e.g., School of International Arbitration, CCLS, Queen Mary University of London and PricewaterhouseCoopers LLP, London, International Arbitration International Arbitration: Corporate Attitudes and
Practices 2006 at 5 (the empirical study conducted demonstrated that 73% of corporations prefer international arbitration, either standalone or combined with ADR, to resolve their cross-border disputes, 16% prefer ADR and 11% litigation). 25 Non-binding court-annexed arbitration is being widely used in several of the U.S., Australia, Canada and New Zealand. See further the court-annexed ODR schemes such as the Singaporean eADR and eCDRI, http://app.subcourts.gov.sg/e-adr/index.aspx. 26 Supra Note 9 33.
27
Janet Rifkin, Online Dispute Resolution: Theory and Practice of the Fourth Party (2001) 19(1) Conflict Resol. Q. 117124. 28 The Uniform Domain-Name Dispute-Resolution Policy (UDRP), available at ICANN website: http://www.icann.org/en/udrp/udrp.htm, establishes both a process and a set of rules for deciding domain name disputes. 29 See Colin Rule and Chittu Nagarajan, Leveraging the Wisdom of Crowds: The eBay Community Court and the Future of Online Dispute Resolution (Winter 2010) ACResolution Magazine, available at: http://www.law.northwestern.edu/colloquium/negotiation/documents/ColinRule_ACRTheWisdomofCrowds.pdf; See also at James Silkenat et al. (eds), The ABA Guide to International Business Negotiations: A Comparison of Cross-cultural Issues and Successful Approaches (2009: Illinois, ABA Publishing) at 235. 30 http://www.cybersettle.com/pub/home/about.aspx. 31 For a list of ODR providers, see: http://www.odr.info/providers.php. 32 Patrikios, Antonis. The Role of Transnational Online Arbitration in Regulating Cross-border E-business. Computer Law & Security Report, 24(1):6676, 2008.
Draft Model Law/Cooperative Framework for Electronic Resolution of Cross-Border E-Commerce Consumer Disputes at 1, available at: http://www.oas.org/dil/esp/CIDIPVII_doc_trabajo_gt_proteccion_consumidor_anexo_A__Borrador_Ley_Marco_Cooperativo_Modelo_Solucion_Ele ctro.pdf.
10
Leigh, Doug and Rule, Colin. Communiqu on the ODR and Consumers Colloquium, held in Vancouver, BC, Canada from November 2-3, 2010 at 2. 35 Ibid. 36 At present, two primary proposals have been advanced: one by Brazil, which assumes that lowvalue, high volume disputes will be resolved in domestic courts, with the law of the consumers residence governing the transaction, and the other is by the United States, Supra Note 33.
11
VI.
There remain many legal issues37 to be overcome in designing a global ODR system, and the upcoming dialogues present a timely opportunity to produce workable solutions to these issues. This essay will focus on the two primary challenges of funding and enforcement of ODR resolutions. Each will be discussed in turn in this section.
A.
Funding
Consumer access to justice in the context of cross-border B2C disputes is one of the most avowed
principles of ODR38. Nonetheless, the practicality of the situation is that consumer access will often have to be reconciled with the financial viability of the undertaking. In the present ODR climate, service providers are generally funded in accordance with one of three business models: bilateral user fees, unilateral user fees, or external funding39. These various models will be discussed in turn, and in the process of discerning an appropriate funding model, it should be borne in mind that a suitable financial structure for a global B2C ODR system will need to possess the twin qualities of cost-efficiency, as well as independence, both actual and perceived, of ODR providers. Under the bilateral user fees model, both parties pay a proportion of the charges, which can vary from one provider to another 40. Notwithstanding its ease of implementation, such a model is not conducive for an ODR system oriented towards B2C disputes, since the costs involved are typically
37
Due to space constraint, this section will only discuss the legal issues that surround ODR, although it is acknowledged that there are other extralegal issues that have been debated in the literature, such as security (see, e.g., Julia Hrnle, Online Dispute Resolution The Emperor's New Clothes? Benefits and Pitfalls of Online Dispute Resolution and its Application to Commercial Arbitration (2003) 17(1) International Review of Law, Computers & Technology 2736 at 30) and the lack of a personal touch in ODR proceedings (See, e.g., Supra Note 17 at 337342; David Larson, Online Dispute Resolutions: Do You Know Where Your Children Are? (2003) 19 Negotiation Journal 199205; and Philippe Gilliron, From Face-to-Face to Screen-to-Screen: Real Hope or True Fallacy? (2007) 23 Ohio St. J. on Disp. Resol. 301344 at 325). 38 See, e.g., Online Dispute Resolution Standards of Practice recommended by the Advisory Committee of the National Centre for Technology and Dispute Resolution, available at: http://www.icann.org/ombudsman/odrstandards-of-practice-en.pdf. 39 Thomas Schultz, Online Dispute Resolution: An Overview and Selected Issues United Nations Economic Commission for Europe Forum on Online Dispute Resolution, Geneva, June 6-7, 2002 at 3.3. 40 Karim Benyekhlef and Fabien Glinas, Online Dispute Resolution (2005) 10(2) Lex Electronica 1129 at 82.
12
41
Thomas Schultz et al., Online Dispute Resolution: The State of the Art and the Issues, Report of the ECom/Law Research Project on ODR of the University of Geneva, December 2001, 1102 at 75. 42 For e.g., In December 1999, Robert Plan Corporation, an auto insurance service underwriter, selected Cybersettle.com as its exclusive ODR provider and agreed to submit at least 15,000 claims through Cybersettle system by the end of 2000. 43 Thomas Schultz, An Essay on the Role of Government for ODR, Theoretical Considerations About the Future of ODR (August 2003) ADROnline Monthly 112 at 7. 44 Pablo Corts, Online Dispute Resolution for Consumers in the European Union (2011: London, Routledge) 2.2.6.2.
13
Ibid 2.3.2.1. Supra Note 8 at 238239. 47 Michael Geist, Fair.com?: An Examination of the Allegations of Systemic Unfairness in the ICANN UDRP (August 2001) at 28, available at: http://aix1.uottawa.ca/~geist/geistudrp.pdf. 48 See section VIII.
14
Supra Note 8 at 230. Convention on the Recognition and Enforcement of Foreign Arbitral Awards, entered into force on June 10, 1959, available at: http://www.uncitral.org/uncitral/en/uncitral_texts/arbitration/NYConvention.html. 51 See, e.g., Gail Lasprogata, Virtual Arbitration: Contract Law and Alternative Dispute Resolution Meet in Cyberspace (2001) 19 Journal of Legal Studies Education 170140; See also Supra Note 26 36. 52 Lasprogata, Ibid at 120.
15
53
Lucille Ponte, Throwing Bad Money after Bad: Can Online Dispute Resolution (ODR) Really Deliver the Goods for the Unhappy Internet Shopper (2001) Tul. J. Tech. & Intell. Prop. 5592 at 88 (It is also suspect whether a court in another jurisdiction will agree to enforce a decision reached in cyberspace that does not comport with established legal, ADR, and public policy standards). 54 Thomas Schultz, Online Arbitration: Binding or Non-Binding? (November 2002) ADROnline Monthly 122 at 7; Jasna Arsic, International Commercial Arbitration on the Internet Has the Future Come Too Early? (1997) 14 J. Intl. Arbit. 209 at 217; Edwards and Wilson, Supra Note 17 2.2.2.1. 55 Supra Note 9; See also The UNCITRAL Working Group on Electronic Commerce 39th Session, 11-15 March, 2002, 152: Difficulties for the use of electronic communications may result, in particular, from the requirement, in article IV, paragraph 1, that, in order to obtain recognition and enforcement of an arbitral award, the moving party must supply: (a) the duly authenticated original award or a duly certified copy thereof; and (b) the original agreement referred to in article II of a duly certified copy thereof. In view of the growing interest in online dispute settlement mechanisms, sub-paragraph (a) of this provision may be a source of legal uncertainty, in particular in States that have not enacted legislation implementing the Model Law on Electronic Commerce, in particular its article 8, or do not other-wise provide for the functional equivalence between data messages and paper-based originals.
16
Supra Note 51 at 1. Henry Perritt, Towards a Hybrid Regulatory Scheme for the Internet (2001) U. Chi. Legal F. 215322 at 237. 58 Supra Note 51 at 8. 59 Frank Cona, Application of Online Systems in Alternative Dispute Resolution (1997) 45 Buff. L. Rev. 975 999 at 993. 60 Robert Bordone, Electronic Online Dispute Resolution: A Systems Approach Potential, Problems, and a Proposal (1998) 3 Harv. Negotiation L. Rev. 175211 at 206 (the author suggests the temporary or permanent loss of cyberspace citizenship rights as ways to enforce ODR results).
17
Llewellyn Joseph Gibbons, Creating a Market for Justice; a Market Incentive Solution to Regulating the Playing Field: Judicial Deference, Judicial Review, Due Process, and Fair Play in Online Consumer Arbitration (2002) 23 New Jersey International Law & Business 164 at 28 (quoting, in part, Christopher Drahozal, Unfair Arbitration Clauses (2001) Uni. Ill. L. Rev. 696 at 796); see also Ethan Katsh et al., E-Commerce, E-Disputes, and E-Dispute Resolution Systems: In the Shadow of eBay Law (2000) 15 Ohio St. J. on Disp. Resol. 705734 at 714; see also Thomas Schultz, Does Online Dispute Resolution Need Governmental Intervention? The Case for Architecture of Control and Trust 6(1) N.C.J.L. & Tech. 71106 at 82. 62 Robert C. Ellickson, Order Without Law: How Neighbors Settle Disputes (1994: Massachusetts, Harvard University Press). 63 Sun Hongfei et al., The Customer Loyalty Research Based on B2C E-Commerce Sites Paper presented at the 2010 National Conference on E-Business and E-Government. 64 Katsh et al., Supra Note 58 729. 65 Ibid.
18
For a detailed examination of these various self-enforcement mechanisms, see Supra Note 11 at 223233; see also Janynefrances Walusimbi Nabawanuka Development of a Self Enforceable Online Arbitration System is the Key to Effective Online Dispute Resolution (ODR) (February 2006) University of Cape Town LLM Thesis 1136 at 97101. 67 European Commission, European Governance: A White Paper COM(2001) 428 final, 25 July 2001 at 21, available at: http://ec.europa.eu/governance/white_paper/en.pdf.
19
Susan Nauss Exon, The Internet meets Obi-Wan Kenobi in the court of next resort, (2002) 8 Boston University Journal of Science and Technology Law 136 at 9. 69 Supra Note 34 at 34.
20
Recommendations71) are instructive and can serve as a useful reference for the purposes of developing this scheme. Salient principles under the recommendations are, inter alia, impartiality, transparency, effectiveness, procedural fairness and independence. In the event of non-compliance with an arbitral award or binding ODR resolution, the successful party can seek enforcement by applying over the Internet to the cybercourt located in the non-complying partys country of domicile for a court order. Local enforcement agencies will then pursue compliance with the resolution either by taking direct enforcement action, requesting assistance from payment networks, or referring cases to collection agencies. De facto enforcement for other forms of non-binding ODR resolutions will be effected through self-enforcement mechanisms.
European Commission Recommendation of 30 March 1998 on the principles applicable to the bodies responsible for out-of-court settlement of consumer disputes (1998/257/CE), available at: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:31998H0257:EN:HTML. 71 European Commission Recommendation of 4 April 2001 on the principles for out-of-court bodies involved in the consensual resolution of consumer disputes (2001/310/CE), available at: http://eurlex.europa.eu/LexUriServ/LexUriServ.do?uri=CELEX:32001H0310:EN:HTML.
21
22
X. Bibliography
Books
Brown, Henry and Marriott, Arthur. ADR Principles and Practice, 2nd ed. London: Sweet & Maxwell, 1999. Corts, Pablo. Online Dispute Resolution for Consumers in the European Union. London: Routledge, 2011. Ellickson, Robert C. Order Without Law. Massachusetts: Harvard University Press, 1991. Hrnle, Julia. Cross-Border Internet Dispute Resolution. Cambridge: Cambridge University Press, 2009. Horvath, August et al. Consumer Protection Law Developments. Illinois: ABA Publishing, 2009. Katsh, Ethan and Rifkin, Janet. Online Dispute Resolution: Resolving Conflicts in Cyberspace. California: Wiley, 2001. Kaufmann-Kohler, Gabrielle and Schultz, Thomas. Online Dispute Resolution: Challenges for Contemporary Justice. The Hague: Kluwer Law International, 2004. Lloyd, Ian. Information Technology Law, 4th ed. Oxford: Oxford University Press, 2004. Redfern, Alan and Hunter, Martin. Law and Practice of International Commercial Arbitration, 4th ed. London: Sweet & Maxwell, 2004. Reed, Chris. Internet Law, 2nd ed. Cambridge: Cambridge University Press, 2004. Rule, Colin. Online Dispute Resolution for Business: B2B, E-Commerce, Consumer, Employment, Insurance and Other Commercial Conflicts. California: Jossey-Bass, 2002. Silkenat, James et al. (eds). The ABA Guide to International Business Negotiations: A Comparison of Cross-cultural Issues and Successful Approaches. Illinois: ABA Publishing, 2009. Solovay, Norman and Reed, Cynthia. The Internet and Dispute Resolution: Untangling the Web. New York: Law Journal Press, 2003. Wang, Faye Fangfei. Online Dispute Resolution: Technology, Management and Legal Practice from an International Perspective. Oxford: Chandos, 2009.
23
24
25
Ramasastry, Anita. Government-to-Citizen Online Dispute Resolution: A Preliminary Enquiry. Wash. L. Rev. 79:159174, 2004. Rifkin, Janet. Online Dispute Resolution: Theory and Practice of the Fourth Party. Conflict Resol. Q., 19(1):117124, 2001. Rule, Colin et al. Designing a Global Consumer Online Dispute Resolution (ODR) System for CrossBorder Small Value-High Volume Claims OAS Developments. Uniform Commercial Code Law Journal, 42:221255, 2010. Rule, Colin and Nagarajan, Chittu. Leveraging the Wisdom of Crowds: the eBay Community Court and the Future of Online Dispute Resolution. ACResolution Magazine (Winter 2010). Available at: http://www.law.northwestern.edu/colloquium/negotiation/documents/ColinRule_ACRTheWisdomofCro wds.pdf. Schultz, Thomas. An Essay on the Role of Government for ODR: Theoretical Considerations about the Future of ODR. ADROnline Monthly, 112, August 2003. Schultz, Thomas. Does Online Dispute Resolution Need Governmental Intervention? The Case for Architecture of Control and Trust. N.C.J.L. & Tech. 6(1):71106, 2004. Schultz, Thomas. Online Arbitration: Binding or Non-Binding? ADROnline Monthly 122, November 2002. Svantesson, Dan Jerker B. Geo-location Technologies and Other Means of Placing Borders on the Borderless Internet. (2004) Law papers. Paper 63. Tang, Zheng. An Effective Dispute Resolution System for Electronic Consumer Contracts. Computer Law & Security Report, 23(1):4252, 2007. Tyler, Melissa and Bornstein, Jackie. Accreditation of On-line Dispute Resolution Practitioners. Conflict Resolution Quarterly, 23(3):383404, 2006. Van den Heuvel, Esther. Online Dispute Resolution as a Solution to Cross-border E-disputes: An Introduction to ODR (August 2000). Available at: http://www.oecd.int/dsti/sti/it/secur/act/online_trust/vandenheuvel.pdf. Wentworth, Elisabeth. Online Dispute Resolution: Global Issues and Australian Standards Towards a Global Best Practice Model for B2C Online Dispute Resolution. The Arbitrator and Mediator, 21(2): 21 38, 2002.
Others
A/CN.9/706 Note by the Secretariat Accompanying the United Nations Commission on International Trade Law, 43rd Session, Possible future work on online dispute resolution in cross-border electronic commerce transactions (New York, 21 June 9 July, 2010), available at: http://daccess-ddsny.un.org/doc/UNDOC/GEN/V10/531/00/PDF/V1053100.pdf?OpenElement.
26
27
28