"internal affairs doctrine"

For readers who follow the law regarding forum selection clauses, a recent article by Professor Joseph Grundfest should be of interest. The good professor addresses the December 2018 Court of Chancery decision in Sciabacucchi v. Salzberg (highlighted on these pages), and the intersection of Delaware law and Federal law in the context of

Sagarra Inversiones, S.L. v. Cementos Portland Valderrivas, S.A., No. 425,2011 (Del. Supr., Dec. 28, 2011), read opinion here. The Chancery decision appealed from was highlighted on these pages here. A related Chancery decision in this case was summarized on this blog here. 

Issue addressed:  Whether the pre-suit demand requirements of Spanish law or