3.3 Renvoi

3.3.1 Concept and Types The concept (the "returning"): the reference-back (the forum's-choice-rules-point-to-the- foreign's-whole-law (the choice-rules-included (the foreign's-rule-points-back...))); the mechanism's-example (the English-domicile-vs-the-French-nationality (the classic's-loop (the testament's-lore))); The types: the remission (the return-to-the-forum's-own-law (the first- rebounce (the forum's-law-applies))); the transmission (the third-law's-destination (the onward-to- another's (the two-step's))); the total-renvoi (the whole-choice-law's (the England's-practice)); the single-renvoi (the first-reference's-stop (the France's-style)); the no-renvoi (the substance-only (the rule-points-to-the-foreign-substantive (the majority's-modern-avoidance))). 3.3.2 Contemporary International Practices and Relevance of Renvoi The codified-poles (the Rome-I's-exclusion (the EU's-no (the certainty's-choice)) vs the retention's- world (the England-and-the-France's (the flexibility's))); the treaty's-avoidance (the Hague's- instruments (the substance-only's-rules)); the modern's-verdict (the renvoi's-decline (the certainty- and-the-predictability's-era (the exam's-critical-point: the doctrine's-cleverness-vs-its- unpredictability))).