Bibliographic record
Abstract
The Lloyd's litigation saga has met the same end in Canada as it has in most American jurisdictions. English judgments against foreign investors (Names) have been recognized in the defendants' home jurisdiction despite challenges based on public policy. Using the latest Ontario case as a starting point, the author examines the public policy arguments surrounding the litigation, from the original enforcement of contractual choice-of-jurisdiction clauses to the final decision to enforce the resulting foreign judgment. The author questions the usefulness of a public policy analysis at the initial jurisdictional stage. She argues that an approach based on the concept of mandatory rules (also known as lois d'application immediate or lois de police) is preferable as it allows for a more coherent examination of the legislative and judicial policies at stake. The argument for recognition based on international comity is then considered. The author argues that precedence granted to party autonomy and international comity is difficult to reconcile with the Ontario court's findings on the fundamental nature of its securities regulation. The author concludes that the Canadian court may have been overly concerned not to deviate from the path set by American courts, thereby subordinating domestic policy to the perceived imperatives of international comity.
Fetched live from OpenAlex and de-inverted. Abstracts are not stored in this database: the inverted indexes are 8.6 GB of the frame’s 9.3 GB of text, and the host has 13 GB free.
How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.002 | 0.006 |
| Meta-epidemiology (narrow) | 0.000 | 0.000 |
| Meta-epidemiology (broad) | 0.000 | 0.000 |
| Bibliometrics | 0.001 | 0.002 |
| Science and technology studies | 0.011 | 0.019 |
| Scholarly communication | 0.012 | 0.005 |
| Open science | 0.001 | 0.002 |
| Research integrity | 0.004 | 0.003 |
| Insufficient payload (model declined to judge) | 0.004 | 0.000 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".