Discuss (c) Mancini

The meaning: the conflict of laws = the domestic law's branch dealing with private-law cases containing a FOREIGN ELEMENT (the foreign party, the foreign situs, the foreign occurrence): which court (the jurisdiction), which law (the choice of law), which judgment (the recognition-and- enforcement) — the three questions of every conflict case. The nature (the classical debate): is it international law or domestic law? — the answer: a DOMESTIC law's branch (each state's own conflict rules; the "private international law" the misnomer retained (Manni's classic: "a misnomer... it is private law") beside the "conflict of laws" the truer name); the international sources' growth (the treaties' unification — the Hague Conventions' family) modifying but not displacing the domestic character.