(F): system by which the arbitral tribunal first determines the applicable private international law, which then determines the applicable substantive law. Example: The arbitral tribunal shall apply the conflict of laws rules that it considers the most appropriate. Contrast using a conflict-of-laws rule provided by the lex arbitri (L)

(F): system by which the arbitral tribunal first determines the applicable private international law, which then determines the applicable substantive law. Example: The arbitral tribunal shall apply the conflict of laws rules that it considers the most appropriate. Contrast using a conflict-of-laws rule provided by the lex arbitri (L)