Questione giuridica chiave
Whether the insurance contract was governed by Swiss consumer-contract conflict rules or by French law under Article 117 LDIP.
Decisione estratta
The contract was not a consumer contract within Article 120 LDIP; French law applied under Article 117 LDIP because the insurer provided the characteristic performance and was established in France.
Motivazione estratta
Insurance for liability arising from ULM use was not a 'common consumer service,' especially since ULM flights were prohibited in Switzerland. Thus the special consumer rule did not displace the general conflict rule.