L1 syndrome should be considered in the differential diagnosis of intellectual disability or mental retardation in children, especially when other signs such as hydrocephalus or adducted thumbs are present.
In contemporary practice, the field of private international law sweeps far beyond the traditional categories of jurisdiction, choice of law, and enforcement of judgments. Today, efforts are underway in several international fora to modernize and harmonize laws which affect individuals and entities in the fields of commercial, financial and family law, transnational litigation, and related areas. This report summarizes a number of recent developments in four of those venues: the Hague Conference on Private International Law (Hague Conference), the UN Commission on International Trade Law (UNCITRAL), the International Institute for the Unification of Private Law (UNIDROIT), and the Organization of American States (OAS). For some topics, more detailed descriptions can be found in other committee reports in this volume.
This first case expresses a postwar yearning for deparochialisation. At stake was the legal effect of a forum-selection clause in an international maritime contract. Decided by the United States Supreme Court in 1972, it marks the beginning of a process of liberalisation of contractual choice of forum, that would extend progressively from adjudication to arbitration. One might say that the siren of free trade lures international jurisdiction into the nets of party autonomy. The dispute arises from a towage contract between an American corporation (Zapata) and a German corporation (Unterweser), in which the main obligation was to move an oil rig from Louisiana to the Adriatic Sea. The contract contained the following forum-selection clause: 'Any dispute arising must be treated before the London Court of Justice.' Unterweser's deep-sea tug Bremen departed Louisiana on 5 January 1968, however, during transportation a severe storm arose while the Bremen was in international waters. The rig was damaged and was towed to Tampa, Florida, the nearest port of refuge. Despite the contractual provisions, on 12 January, Zapata commenced a suit in admiralty in the United States District Court at Tampa, seeking damages against Unterweser in personam and the Bremen in rem, alleging negligent towage and breach of contract. Unterweser invoked the forum clause and moved to dismiss for lack of jurisdiction or on forum non conveniens grounds. Alternatively, the German corporation requested to stay the action pending submission of the dispute to the London Court of Justice. Unterweser commenced an action in the High Court of Justice in London, as the contract provided, and Zapata showed before that court to contest jurisdiction. The English court ruled that it had jurisdiction under the contractual forum provision. In its turn, the United States District Court at Tampa relied on the prior decision of the Court of Appeals in Carbon Black Export, Inc. v. The Monrosa, 254 F.2d 297 ('agreements in advance of controversy whose object is to oust the jurisdiction of the courts are contrary to public policy, and will not be enforced') and denied Unterweser's motion to dismiss or stay Zapata's initial action. The Court of Appeals affirmed that the forum-selection clause was unenforceable. Unterweser sought review in Supreme Court on certiorari and it was granted. The U.S. Supreme Court held that the forum-selection clause is binding on the parties unless the party seeking to avoid it could meet the high burden of showing it to be unreasonable, unfair, or unjust.
We present three cases of patients who devel-oped acute, non-severe myocarditis following messenger RNA-1273 vaccine from Moderna (Moderna Inc.) against the severe acute respiratory syndrome coronavirus 2 (SARS-CoV-2). A brief review of the literature, diagnostic modalities, work-up and treatment are discussed.
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