Questão jurídica principal
Whether the parties' contract was governed by Swiss law by tacit choice of law
Decisão extraída
Yes. Both parties invoked Swiss law in the proceedings, allowing a tacit choice of law under the trust principle.
Fundamentação extraída
The court found that the claimant had expressly argued for Swiss law and the respondent had expressly accepted it, which objectively manifested a common intention to submit the dispute to Swiss law.