Evolution and Trends of Manifestations of Sovereignty in Private International Law:Taking American Choice-of-law Approaches as An Example

Because of different understandings of the contents of sovereignty in different countries with regard to the internal and external sovereignty,and different patterns of realization of their internal and external sovereignty,the sovereignty characteristics of private international law in different countries are different.From a historical perspective and in connection with sovereignty factors,an analysis is made here about the significance of territorial and personal jurisdiction in traditional private international law.In American theory ofconflict-of-law revolution,with the emphasis on the content of the entity law and the consideration of the law selection policy,the connotations of the different internal sovereignty are embodied in the approaches to the private international law.On the basis of the analysis above,a conclusion is given that the special choice-of-law policies adopted by a certain country are essential for its adoption of choice of law approaches or the enactment of choice of law rules.Lastly,the author's points of view are given with regard to choice-of-law problems concerning sovereignty.