Outside CounselAndrew Hutcheon and Mark Lee , New York Law Journal
Choice-of-Law Considerations in Transatlantic Transactions
Andrew Hutcheon and Mark Lee write: There are subtle differences between the approaches of New York and English law as to whether the courts will step in to "complete" preliminary or incomplete agreements where material terms are left to be agreed. One such difference is whether a preliminary agreement creates a duty to negotiate any remaining open terms in good faith.
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