The analysis of Private International Law is

characterized by a structured approach. Although national Private International

Law systems differ, the main elements of this approach have found acceptance in

many jurisdictions. On the other hand, the doctrine of Private International

Law is still occupied with questions as what is the proper basis for a rule on

Private International Law. An example is the principle that should be at the

heart of a choice of law rule, should it designate the law that is closest

connected to the case, should it protect certain interests or should it direct

to the