聚焦CAS“商事性”裁决，透视外国仲裁裁决在我国的承认与执行

2020-06-17 15:48:50 373

The Recognition and Enforcement of Foreign Arbitral Awards in China: Focusing on the Commercial Reservation from a CAS Award

The United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards (“New York Convention”)[1] is one of the key instruments in international arbitration, applying to “the recognition and enforcement of foreign arbitral awards and the referral by a court to arbitration”.[2] It was determined at the 18th session of the Standing Committee of the 6th National People’s Congress on December 2, 1986 that the People’s Republic of China (“PRC”) shall enter the New York Convention, and it was effective as of April 22, 1987.[3] Over the past more than thirty years, the New York Convention has paved the way for Chinese courts to decide on cases involving the recognition and enforcement of foreign arbitral awards.

China made two reservations under the New York Convention. One of these reservations is commercial reservation, which means that the matter subject to arbitration arises out of a commercial legal relationship in accordance with the PRC law. The foreign awards made by the Court of Arbitration for Sports (“CAS”) could serve as a unique example in examining the commercial nature of the dispute in the course of recognition and enforcement of foreign arbitral awards under the New York Convention. This article will discuss the first Chinese case involving the recognition and enforcement of a CAS award, identifying legal issues by analyzing this and cases in other jurisdictions.

CAS Arbitral Awards

The CAS was initially created by the International Olympic Committee (“IOC”) in 1984 and is an independent institution based in Lausanne, Switzerland, providing services to facilitate sports-related disputes through arbitration and mediation. The Code of Sports-related Arbitration (“CAS Code”) governs the arbitration proceeding, setting forth the rules governing the organization of the CAS and all jurisdictional and procedural matters. In terms of the seat of the CAS, unlike many arbitration institutions whose arbitration rules stipulate that the seat of arbitration is variable, the seat of the CAS is Lausanne, Switzerland.[4] A CAS award is usually deemed as a foreign arbitral award in China.

There are two types of arbitral proceedings – the ordinary arbitration procedure and the appeals arbitration procedure. The ordinary arbitration procedure applies to disputes resulting from contractual relations or torts, whereas the appeals arbitration procedure applies to disputes resulting from decisions taken by the internal bodies of sports organizations.[5]

There must be an arbitration agreement reached by disputing parties to have their disputes resolved by the CAS, or the jurisdiction may come from statutes or regulations of sports-related bodies (federations, associations, etc.) which render the decisions.[6] The parties to disputes are entitled to seek either to set aside an award or to refuse to recognize and enforce an award before a foreign court. The action to set aside a CAS award must be lodged with the Swiss Supreme Court, i.e. the Federal Tribunal. Concerning the recognition and enforcement of a CAS award with commercial nature, the New York Convention that was mentioned above provided for a judicial mechanism for foreign courts. We discuss the recognition and enforcement of a CAS award in China by focusing on the Dalian Yifang case.

The Dalian Yifang Case

The first decision made by the PRC court on the recognition and enforcement of award made by the CAS is the Dalian Yifang case. In this case, the Claimants, Juan and Alfonso and the Respondent, Dalian Yifang Football Club Co., Ltd reached a legal service agreement, and after the Claimants represented the Respondent to settle a dispute, the Respondent did not pay the fees agreed in the agreement. Concerning the dispute settlement in this agreement, the parties agreed on an arbitration clause which stipulates that the parties agree to settle disputes through CAS arbitration and the seat of the arbitration is Lausanne. Afterwards disputes arose concerning legal fees, the Claimant commenced arbitration under the CAS, followed by the request made to Dalian Intermediate People’s Court to recognize and enforce the CAS award.

The Respondent claimed:

(1) The arbitration agreement is null and void on the following grounds:

a. The CAS did not have jurisdiction over this dispute, and according to Article V(1)(a) of the New York Convention, the arbitral award should not be recognized or enforced; and

b. The Chinese version of the arbitration agreement did not reflect either parties’ intention to settle disputes under arbitration, and there was serious misunderstanding as to the arbitration agreement, which violated the principle of good faith.

(2) The Respondent failed to be notified with the arbitration procedure and was not entitled to due process to present itself before the tribunal, therefore the award should not be recognized or enforced according to Article V(1)(b) of the New York Convention.

In terms of the validity of the arbitral award, the Court noted that the jurisdiction of arbitration institution is not one of the grounds to nullify an award under Article V(1)(a) of the New York Convention.[7] Also, it was held that the PRC courts do not have the obligation to review the competence of foreign arbitration institutions based on Article 274 of the Civil Procedural Law of the PRC[8] and Provisions of the Supreme People’s Court on Several Issues concerning Trying Cases of Arbitration-Related Judicial Review[9]; even if they had, the Court recognized the CAS’s jurisdiction in this case.[10] According to Article R27 of the CAS Code[11], it applies “whenever the parties have agreed to refer a sports related dispute to CAS”, and “such disputes may involve matters of principle relating to sport or matters of pecuniary or other interests relating to the practice or the development of sport may include, more generally, any activity or matter related or connected to sport”. Since the parties reached the agreement to settle this dispute under the CAS and, the issues arising concern the counsel fees regarding a sports dispute under the CAS, the Court recognized that the identities of both parties (sports lawyers and a sports club) as well as the legal services fell into the scope of sports, and therefore the CAS has jurisdiction under this case.[12] Furthermore, the tribunal itself reviewed its competence which could be indicated in part 5 of the award, stating that both parties agreed to settle disputes under the CAS according to the arbitration agreement and that the Respondent did not challenge its jurisdiction.

When it comes to the second ground concerning the differences between the agreement’s Chinese and English versions and the Respondent’s misunderstanding, the Court held that according to PRC law[13] and the agreement, the validity of the award should be decided according to Swiss law. Since the Respondent did not submit any evidence concerning the validity of the award under Swiss law, the Court did not accept this ground.

For the delivery of arbitration notice, the CAS sent the documents to the Respondent’s address according to the registration information, which is the same as the one in the correspondence with the Claimants and the one in the agreement. The related notices and documents were duly received and the procedure is consistent with Article R31 of the CAS Code.[14] Also, the Respondent did not notify the CAS and the Claimants of the change of the address. Therefore, this ground for refusing to recognize and enforce this award is also invalid.

Subsequently, the Respondent filed an objection with the Court, requesting the Court to set aside the above-mentioned Ruling. It claimed in the written objection that the enforcement of this Ruling would be inconsistent with the Minutes of the Meeting of the Municipal Government of Dalian, according to which Dalian Aerbin Football Club Co. Ltd. and Zhao Yangming undertook to pay the pre-transfer liabilities. Under this circumstance 100% equity was transferred to Dalian Yifang, which took place after the arbitral award was made. Therefore, it was claimed that Aerbin and Zhao Yangming should be responsible for the liabilities. The objection was overruled on the basis that it falls outside of the scope of the review, and that there is no legal basis in the Chinese execution procedure to set aside a foreign arbitral award that has been recognized and enforced.[15]

Cases in other Jurisdictions concerning the CAS Appeals Arbitration

Up to now, since there has been no such decision as to the recognition and enforcement of “non-commercial” CAS awards from the appeals arbitration procedure in China, it is worthwhile to note decisions from other jurisdictions,[16] which could provide for guiding values for the PRC courts, especially when there is growing needs for a “uniform global lex sportiva”.

Despite the fact that the United States made the commercial reservation under the New York Convention, the US courts seem to adopt a relatively broad approach. Both Slaney v. International Amateur Athletic Federation[17] and Gatlin v. U.S. Anti-Doping Agency, Inc[18] involve doping disputes and neither Courts mentioned whether the disputes are commercial. Instead, in both cases the public policy concerns under the New York Convention were raised.

Similarly, in Meca-Medina & Majcen v. Commission of European Communities[19], the European Court of Justice (“ECJ”) recognized that the doping rules have the requisite effect on economic activity by banning them from professional swimming, rather than being “purely sporting in nature”. In contrast, the Belgian Court held that arbitration rules set out in statutes of Fédération Internationale de Football Association (“FIFA”), Union of European Football Associations (“UEFA”) and their member federations to oblige legal disputes to be heard exclusively by CAS, are illegal,[20] and is a violation of Article 6 of the European Convention of Human Rights[21] and Article 47 of the Charter of Fundamental Rights of The European Union[22]. This decision cast doubt on the legality of the compulsory nature of statutes and rules of associations and clubs and also questioned the appeals arbitration procedure of the CAS.

Future Prospects of the Recognition and Enforcement of CAS Awards in China

Since the PRC made two reservations based on Article I (3) of the New York Convention when acceding, one of which provides that the PRC will apply the Convention only to differences arising out of legal relationships, whether contractual or not, which are considered as commercial under the national law of the PRC, distinguishing commercial and non-commercial CAS awards should be paid attention to. It is argued that non-commercial CAS awards, i.e. a disciplinary nature following a decision by a sports organization (e.g. a doping case),[23] should not be recognized by the PRC courts under the New York Convention on the basis that they fall into the scope of administration and jura personarum.[24] Also, even if the reservation was withdrawn, the awards would still not be recognized based on Article 2 of the Arbitration Law of the PRC[25] and Article V(2)(a) of the New York Convention[26]. Should recognition and enforcement of non-commercial CAS awards be sought before PRC courts, it is highly likely that the recognition and enforcement would be refused.

Whether to recognize and enforce the non-commercial CAS awards in China will expect to become a concern for PRC courts as the matter comes without legal basis. More disciplinary disputes are expected to arise and related CAS awards will face judicial reviews in China, so there is growing need to issue some judicial guidelines with a normative value.[27] Universally accepted legal rules and dispute resolution processes which are fair and equitable on a worldwide basis are called for to promote the development of a single uniform legal regime for international sports competition.[28] Therefore a supportive attitude may need to be adopted towards future sports-related disputes and CAS awards.

Conclusion

The Dalian Yifang case as the first case concerning the recognition and enforcement of a CAS commercial award in China not only indicates the basis of the New York Convention, but also plays an important role for the PRC courts to model on in future cases of dealing with foreign arbitral awards involving commercial disputes.

As to future CAS awards involving doping and other disciplinary disputes which may not be recognized and enforced in China for their non-commercial nature, it is still disputable. If a CAS award involving doping and disciplinary matters is not recognized and enforced in China, what does this mean to the CAS award as far as the disciplinary decisions are concerned in China? Clearly there is room for future discussion.

中文版

聚焦CAS“商事性”裁决，透视外国仲裁裁决在我国的承认与执行

《承认与执行外国仲裁公约》（以下简称“《纽约公约》”）是国际仲裁领域最重要的公约之一，适用于外国仲裁裁决的承认与执行以及法院指令按仲裁协议进行仲裁的情形。1986年12月2日，中华人民共和国第六届全国人民代表大会常务委员会第18次会议批准中国加入该公约，自1987年4月22日正式生效。过去的30多年间，《纽约公约》为中国法院在承认与执行外国仲裁裁决的实践中起到了指导性作用。

在加入该公约时，中国作出了两项保留。其中一项是商事保留，根据我国法律只对商事法律关系适用该公约。实践中，根据《纽约公约》对于国际体育仲裁院（CAS）裁决的承认与执行的案例对于我们分析该商事保留起到重要作用。本文探讨了中国首例承认与执行CAS裁决的案例，并结合其他司法管辖区域的案例对相关法律问题作出分析。

CAS裁决

国际体育仲裁院最初是国际奥林匹克委员会（IOC）于1984年建立的独立机构，总部设在瑞士洛桑，旨在处理体育相关争议的仲裁与调解业务。《体育仲裁法典》对于仲裁的程序性问题作出了详细的规定。而对于仲裁地问题，不同于其他仲裁机构规则的规定，CAS裁决的仲裁地是瑞士洛桑。CAS的裁决，相对于中国而言，通常为外国仲裁裁决。

CAS有两种仲裁程序——普通仲裁程序与上诉仲裁程序。普通仲裁程序适用于一裁终局的契约性或侵权性的民商事纠纷，而上诉仲裁则适用于对国际体育机构内部决定提出上诉后的终局程序。

只有存在仲裁协议的前提下，争议双方才能把争议提交CAS。CAS的管辖权依据也来源于国际体育机构的强制性规定。裁决作出后，争议一方有权在瑞士以外的国家法院提起承认与执行该裁决的诉讼请求，或者向瑞士联邦法院提起撤销该裁决的诉讼请求。CAS的民商事裁决的承认与执行参照《纽约公约》相关规定。本文通过分析“大连一方案”探讨CAS裁决在中国的承认与执行相关法律问题。

“大连一方案”

“大连一方案”是中国首例对CAS裁决承认与执行的案例。该案中，申请人胡安、阿尔方索与被申请人大连一方足球俱乐部有限公司签订了一份《法律服务合同》。申请人代表被申请人应诉后，被申请人未根据该合同向申请人支付律师费。根据该合同包含的仲裁条款，双方同意将本协议提交国际体育仲裁院管辖，仲裁地为洛桑。争议发生后，申请人根据仲裁条款将争议提交CAS。裁决作出后，申请人向大连市中级人民法院申请承认与执行该CAS裁决。

被申请人称：

（1）仲裁条款无效。

a. CAS裁决所处理的争议超出了仲裁机构的管辖范围，符合《纽约公约》第五条第一款（甲）项规定的情形，依法应拒绝承认与执行。

b. 协议中文文本中并未体现仲裁管辖的约定，其在不知情的情况下签订仲裁管辖条款，该协议违反了诚实信用原则，应属无效。

(2) 其从未收到过CAS的关于仲裁程序的有效、适当通知，导致其未能申辩。案涉仲裁裁决符合《纽约公约》第五条第一款（乙）项规定的情形，依法应当裁定驳回申请，拒绝承认与执行。

关于第一项理由，法院认为仲裁机构是否有管辖权，并不属于《纽约公约》第五条第一款（甲）项所列情形。此外，根据《中华人民共和国民事诉讼法》第274条、《最高人民法院关于审理仲裁司法审查案件若干问题的规定》，法院并无义务审查外国仲裁机构的管辖权问题。即使要讨论CAS对于本案的管辖权，法院的答案也是肯定的。《体育仲裁法典》第R27条规定，“只要当事方同意将体育相关纠纷提交给CAS，本程序规则即适用……此类纠纷可能涉及与体育有关的原则性问题或与体育活动的实践或发展有关的金钱利益或其他利益，涵盖与体育有关的任何活动或事项”。大连法院认为，当事人签订了合法有效的仲裁协议，并且无论是双方的身份（体育法律师与足球俱乐部），还是所涉法律服务的内容（与体育争议有关的律师费），均与体育有关，CAS对本案有管辖权。其次，在裁决书第五部分"中，仲裁庭认为当事方同意在出现关于合同的纠纷时接受CAS的管辖。被申请人未对CAS裁决纠纷的权限提出质疑。所以，法院认为，CAS是裁决纠纷的适当机构。

关于第二项理由，法院认为，根据中国法与当事人约定的准据法，对仲裁协议是否成立、仲裁条款效力的审查应适用瑞士法律。被申请人并未提交根据瑞士法律该仲裁协议不成立或无效的证据，故不予采纳"中英文文本差异巨大"导致仲裁条款无效的理由。

关于仲裁通知是否有效送达的问题，CAS根据注册地址向被申请人进行了文书送达，该地址与其在与申请人进行沟通所发函件及合同中注明的公司联系地址一致。被申请人已签收文件，并且该送达程序符合《体育仲裁法典》第R31条规定。此外，被申请人均未通知CAS或者申请人其联系地址已变更。拒绝承认和执行仲裁裁决的理由不能成立。

该裁定作出后，被申请人向法院申请撤销该裁定书的执行。被申请人称，执行该裁定书将违反市政府会议纪要的相关内容。该纪要中，大连阿尔滨集团有限公司与赵明阳承诺共同承担并负责偿还股权转让前的债务。在此情况下，大连一方集团有限公司收购了阿尔滨集团拥有的大连阿尔滨足球俱乐部100%的股权，并且该转让发生在仲裁裁决作出后。因此，被申请人称，大连阿尔滨集团有限公司与赵明阳应承担案涉债务。法院认为，关于该案执行异议的依据，不属于执行异议的审查范围，也缺乏相应的程序性法律规定作为依据。

在该案中，法院的裁定认可了《纽约公约》作为CAS裁决在我国承认与执行的依据，并为未来我国法院对于涉及商事法律关系的CAS裁决的审查提供了参考。

其他司法管辖区域关于上诉裁决的相关案例

迄今为止，我国尚未出现关于CAS“非商事性”上诉仲裁裁决承认与执行的相关案例。而在“建立国际统一体育法”的时代，其他司法管辖区域法院的相关判决对于我国同样具有参考价值。

例如，尽管美国在加入《纽约公约》时作了商事保留，美国法院在审查裁决时却采用了更为宽松的做法。Slaney v. International Amateur Athletic Federation案与Gatlin v. U.S. Anti-Doping Agency, Inc案都涉及到兴奋剂使用的相关纠纷，而审查法院均未对争议是否具有商事性质作出评价，但均分析了《纽约公约》下的“公共政策”问题。

同样，在Meca-Medina & Majcen v. Commission of European Communities案中，欧洲法院（ECJ）指出，兴奋剂规则不仅仅具有纯粹的体育性质，更因为禁止职业游泳运动员参赛而会对其经济活动有所影响。相反，比利时法院认为，CAS依据国际足球联合会（FIFA）、欧洲足球协会联盟（UEFA）的内部章程进行强制仲裁，违背了《欧洲人权公约》第6条与《欧洲基本权利宪章》第47条，不具有合法性。该判决对协会、联盟的内部章程的强制性规定与CAS的强制仲裁提出了质疑。

CAS裁决在中国承认与执行的前景

我国在加入《纽约公约》中时，根据第一条第三款作出保留。根据该款，“任何国家亦得声明，该国唯于争议起于法律关系，不论其为契约性质与否，而依提出声明国家之国内法认为系属商事关系者，始适用本公约”。所以，应区分CAS裁决的“商事性”与“非商事性”。一些学者认为，对体育组织纪律性决定的上诉（例如，涉及使用兴奋剂的纠纷）因其具有行政性与人身权属性，而不应作为“商事性裁决”在我国得到承认与执行。即使我国撤销了商事性保留，根据《中华人民共和国仲裁法》第二条与《纽约公约》第五条第二款（甲）项，该裁决仍无法在我国得到承认与执行。所以，未来 “非商事性”CAS裁决极有可能在我国被拒绝承认与执行。

由于缺乏法律依据，是否承认与执行“非商事性”CAS裁决，将成为中国法院关注的问题。未来将会出现更多纪律性裁决，并且其中一些裁决将面临在中国的承认与执行问题。因此，我国有必要出台相关司法意见，为之提供指导。越来越多人呼吁为国际体育赛事提供一个公平合理的国际统一机制，包括法律规则与争议解决机制。因此，对于未来体育争议与CAS裁决，我们不妨展现积极的态度。

结语

“大连一方案”是我国首例承认与执行CAS商事裁决的案例，不仅明确了《纽约公约》作为承认与执行CAS裁决的法律依据，更为未来CAS“商事性”裁决在我国的承认与执行提供了参考。

但对于涉及兴奋剂等纪律性争议的裁决，在我国仍存在争议。如果这些裁决在中国得不到承认与执行，这对CAS裁决及纪律性决定意味着什么呢？这些问题仍具有讨论的空间。

References

[1] United Nations Convention on the Recognition and Enforcement of Foreign Arbitral Awards 1958.

[2] New York Arbitration Convention official website, viewed 12 May 2020,.

[3] New York Arbitration Convention, Circular of Supreme People's Court on Implementing Convention on the Recognition and Enforcement of Foreign Arbitral Awards Entered

by China, viewed 12 May 2020,.

[4] Code of Sports-related Arbitration 2019. Article R28 provides, “The seat of CAS and of each Arbitration Panel (Panel) is Lausanne, Switzerland. However, should circumstances so warrant, and after consultation with all parties, the President of the Panel may decide to hold a hearing in another place and may issue the appropriate directions related to such hearing.”

[5] Court of Arbitration for Sport, Frequently Asked Questions, viewed 12 May 2020,.

[6] Code of Sports-related Arbitration 2019, Article R37.

[7] The grounds for refusing the recognition and enforcement of a foreign arbitral award under Article V(1)(a) of the New York Convention is that “the parties to the agreement referred to in article II were, under the law applicable to them, under some incapacity, or the said agreement is not valid under the law to which the parties have subjected it or, failing any indication thereon, under the law of the country where the award was made”.

[8] Civil Procedural Law of the PRC 2017. Article 274 stipulates that a PRC court could refuse to enforce an award only if it is made by an international arbitration institution of the PRC, rather than a foreign arbitration institution.

[9] Provisions of the Supreme People’s Court on Several Issues concerning Trying Cases of Arbitration-Related Judicial Review 2017. This Provisions does not cover the issues concerning the jurisdiction of foreign arbitral awards.

[10] Juan and Alfonso v. Dalian Yifang Football Club co., LTD (2017) Liao 02 Min Chu 583.

[11] Code of Sports-related Arbitration 2019.

[12] Juan and Alfonso v. Dalian Yifang Football Club co., LTD (2017) Liao 02 Min Chu 583.

[13] Article 16 of the Provisions of the Supreme People's Court on Several Issues concerning Trying Cases of Arbitration-Related Judicial Review 2017 provides, “When a people's court relies on the Convention on the Recognition and Enforcement of Foreign Arbitral Awards to review a case in which a party applies for the recognition and enforcement of a foreign arbitral award, if the respondent raises a defense that the arbitration agreement is invalid, the people's court shall, according to paragraph 1(a), Article 5 of this Convention, determine the law applicable to the recognition of the effect of the arbitration agreement”. Article 18 of the Law of the People's Republic of China on Choice of Law for Foreign-related Civil Relationships 2011 provides, “The parties concerned may choose the laws applicable to arbitral agreement by agreement. If the parties do not choose, the laws at the locality of the arbitral authority or of the arbitration shall apply”.

[14] Article R31 stipulates that “all arbitration awards, orders, and other decisions made by CAS and the Panel shall be notified by courier and/or by facsimile and/or by electronic mail but at least in a form permitting proof of receipt”.

[15] Juan and Alfonso v. Dalian Yifang Football Club co., LTD (2019) Liao 02 Zhi Yi 122.

[16] For more details, please see: Mitten, MJ 2009, ‘Judicial Review of Olympic and International Sports Arbitration Awards: Trends and Observations’, Pepperdine Dispute Resolution Law Journal, vol. 10, no. 1, pp. 51-67.

[17] Slaney v. Int’l Athletic Amateur Fed’n, 244 F.3d 580 (7th Cir.), cert. denied, 534 U.S. 828 (2001).

[18] Gatlin v. United States Anti-Doping Agency, Inc., No. 3:08-cv-241/LAC/EMT, 2008 WL 2567657 (N.D. Fla. 2008).

[19] Meca-Medina & Majcen v. Comm’n of European Communities, [2006] 5 C.M.L.R. 18 (ECJ 3rd Chamber 2006).

[20] Diamond, J 2018, Brussels Court Rules “Enforced Arbitration” of CAS is Illegal, Inside the Games, viewed 14 May 2020,.

[21] Article 6 of the European Convention of Human Rights 2010 concerns the right to a fair trial.

[22] Charter of Fundamental Rights of The European Union (2000/C 364/01). Article 47 concerns right to an effective remedy and to a fair trial.

[23] Court of Arbitration for Sport, Frequently Asked Questions, viewed 12 May 2020,.

[24] Fu, P 2019, “Recognition and Enforcement of CAS Awards in China from an Analysis of the ‘Yifang Football Club’ Case”, Journal of Chongqing University of Technology (Social Science), vol. 33, no. 6, p. 108.

[25] Article 2 of the Arbitration Law of the PRC 2017 provides, “Contractual disputes and other disputes over rights and interests in property between citizens, legal persons and other organizations that are equal subjects may be arbitrated”. Parties to the non-commercial awards are sports organizations and athletes under the control of the organizations and the disputes are neither contractual nor property-related so they are likely considered as not arbitrable under the PRC law.

[26] Article V (2)(a) of the New York Convention provides, “Recognition and enforcement of an arbitral award may also be refused if the competent authority in the country where recognition and enforcement is sought finds that the subject matter of the difference is not capable of settlement by arbitration under the law of that country”.

[27] Fu, P 2019, “Recognition and Enforcement of CAS Awards in China from an Analysis of the ‘Yifang Football Club’ Case”, Journal of Chongqing University of Technology (Social Science), vol. 33, no. 6, p. 108.

[28] Mitten, MJ 2009, ‘Judicial Review of Olympic and International Sports Arbitration Awards: Trends and Observations’, Pepperdine Dispute Resolution Law Journal, vol. 10, no. 1, pp. 51-67; Huang, S 2012, ‘Recognition and Enforcement of CAS Arbitral Awards’, Contemporary Law Review, vol. 26, no. 6, p.136.

北京霖理律师事务所是北京市司法局批准设立的律师事务所，主要业务覆盖国际仲裁、知识产权和商事投资合同争议解决。霖理法律英语是“为了法律的目的学习简洁英语”而开创的公众号，是霖理律师事务所涉外业务的研发平台，旨在促进法律英语和中文法律语言的应用和普及，努力打造中文社区内生的法律英语的多元生态，促进复合型法律职业人士交流经验互动学习。

长按下方二维码关注我们