The primary goal of the conflict of laws method of private international law is to
designate the only legal system in an international situation according to which the
given case must be adjudicated on its merits. The instrument for this goal is the
conflict of laws norm, which refers the given situation to the scope of a single legal
system. This paper – in connection with an everyday European company law situation
– examines the problem when the conflict of laws rule simultaneously invokes several
legal systems, and proposes solutions to this second-degree conflict from a private
international law and a European company law perspective.
