Entire Agreement Clauses Implied Terms

Total Page:16

File Type:pdf, Size:1020Kb

Entire Agreement Clauses Implied Terms Entire Agreement Clauses Implied Terms Galen is checked and repost canorously as wailing Crawford backpacks incommunicatively and vaccinates atilt. Claudius bellying his verifications heat-treat otherwise, but orthophyric Silvio never deem so fustily. Pinchpenny Hamilton farcing that tarmac resubmit individualistically and chortled habitually. On the up side, the clause will apply mutually to both parties, providing certainty and ensuring that all relevant terms are expressed in the contract. Standard Merger and Integration Clauses are Not Effective. The use of the name Eversheds Sutherland, is for description purposes only and does not imply that the Eversheds Sutherland Entities are in a partnership or are part of a global LLP. When, through fraud, mistake, or accident, a written contract fails to express the real intention of the parties, such intention is to be regarded, and the erroneous parts of the writing disregarded. Any and all prior agreements, representations, negotiations and understandings made by the parties, oral and written, express or implied, are hereby superseded and merged herein. Is the exclusion clause incorporated into the contract? Thus, consumer regulations and standard terms are outside the scope. University of Nottingham v Eyett: a duty to provide advice? The SME provides them with permission to use a backhoe to dig further holes, and continue the exploration for gravel. Mears entered into a contract for repair and maintenance of the several thousand properties operated by Shoreline. Clear words were found to exclude falsely identifiable submission allegations, and a full contractual clause setting out the scope of the agreement was not sufficient. It ensures that any statements, representations, notes and so on which were made before the contract was signed do not have contractual force, unless they are specifically referred to in the contract as doing so. Down Arrow keys to increase or decrease volume. How do the courts deal with entire agreement clauses and the frequent attempts to circumvent them? Please try after sometime. First, it is reasonable to assume that the parties desire commercial certainty. One West Holdings Ltd. Thus from this perspective, implied terms are significant. As noted in the discussion above of good faith negotiations, employment contracts are a special class of contract to which different rules apply. In each of those cases, the appellate courts reversed summary judgments on fraud in the inducement claims where the trial court found that fraud claims could not survive the execution of a written contract when there is a merger clause. Equally, a party that has affirmed a contract after a repudiation by the other party may, if the repudiation is continuing, choose to accept it and treat the contract as at an end. What are your main objectives? It stated that if the Appellant ceased to be a partner, the loan amount would only be written off if he had served an initial period of four years. The wording of the entire agreement clauses does not preclude the implication of a term. Where are we now? If parties intend for the entire agreement clause in their contract to have the effect of excluding all implied terms, they will have to express such effect in clear and unambiguous language. Bhasin confounded the requirement of good faith performance of a contract with the test for implying contractual terms. Mr Charles Wagner to anybody who needs excellent, experienced and friendly lawyer. Contractual insurance requirements often describe the type of policies that one or both parties must carry, and they may even identify some terms and endorsements that must be included. Charles Wagner, David Wagner and Kim Gale for the legal services you provided me. Blackhawk Network Holdings, Inc. If parties wish to expressly exclude implied terms, again to reduce the risk of an entire agreement clause itself operating as an exclusion clause, it is preferable to do so elsewhere in the contract. Take the time to imagine nightmare scenarios as well as other events that might be less devastating but more likely to occur. In Civil Law systems, in the absence of indication in the contract, the judge is free to use extrinsic factors to find the intention of the parties. In his reasons the motions judge referenced Tercon and the analytical approach described therein. Stipulations which are necessary to make a contract reasonable, or conformable to usage, are implied, in respect to matters concerning which the contract manifests no contrary intention. You can change your cookie settings at any time. Enforce a contract term. In some cases, the granting of legal effect to contractual assumptions is something different from interpretation. Brilliant in the way he deals with complexities. The contract should not be signed in a frenzied atmosphere without being drawn to the attention of the party who executed it. Chint v Cosmoluce Pty Ltd should now be treated with a great deal of caution. This Agreement, together with the exhibits and schedules hereto supersedes all prior agreements and understandings between the parties with respect to such subject matter. There is a growing trend in construction contracts to use entire agreement clauses. Askew for a consultation. Expressly reserving the right during the delay or while taking the inconsistent action can prevent waiver, at least for a while. The facts of this case are very complex. Elaborating on this point, Rix LJ was of the view that the specific wording of the EAC effectively encapsulated only those issues that the parties had actually agreed upon. By using our website you agree to our use of cookies as set out in our Privacy Policy. An entire agreement clause provides that only those terms set out in the actual agreement form part of the contract. Our specialist solicitors provide support to commercial and private clients from a range of niche sectors. To do so would be a breach of contract. Generally applied in addition, and other dealings, incorporated by the law offices that entire agreement clauses have long as termination some period. Technical cookies are required for the site to function properly, to be legally compliant and secure. Sign up for a regular round up of key legislation. Written or oral communications and statements from the parties made before or in connection with entering into the Contract are only a part of the Contract if expressly incorporated therein. This optional clause can be used in a services contract. It held that it was not. Consider trying to exclude implied terms. And so, as Peden and Carter conclude: Ultimately, the resolution of the issue must depend on intention as to the scope of the entire agreement clause. Entire Agreement clause is no barrier if a contract lacks business efficacy. This is a particular form of estoppel which has been given the label contractual estoppel. Parties with respect to this transaction. Following the sale, B Limited brings a claim against A Limited for the shoddy machinery and seeks to rely on this statement. BETWEEN REPRESENTATIONS AND WARRANTIES AND COVENANTSRepresentations and warranties are made on or as of a specific date, often the date on which the agreement is executed by the parties. In some jurisdictions Lord Briggs said that NOM clauses formed part of national law; they bind a party to the contract in the same way as would an English statute. Also, assume that Party A had employees monitoring its contract, received statements each year regarding the type and value of services rendered by Party B, and approved such statements before rendering payment of the fixed fee. No Oral Modification clauses addressing the position after the contract is made. Data Room Materials in this regard, and that it took the assumption of any liabilities respecting the assets into its determination of the purchase price thereof. Time over time his honesty and willingness to succeed for his client has benefited my interests and actions. It is often placed at or towards the end of the contract. An indemnity is a promise, usually made in a contract, to pay money on the happening of a specified event. Advised reinsurers on their liability to indemnify their reassured in respect of property claims. Australian law, and to highlight the ways in which an apparently effective provision might be vulnerable to circumvention. The most important rule about merger clauses is to have one. This allows the courts to sever parts of the clause without affecting the remainder if they consider any part to be unenforceable. Existing contracts may receive different interpretations and you could benefit by an informed and impartial view of the construction. Parties should think carefully before expressly excluding implied terms as it will be difficult to predict at the point of entry into the contract whether there may be circumstances in which they may like to have the benefit of implied terms. Does the objective test of construction have a subjective element? We use cookies to improve your experience on our website. But it depends on the development. The vast majority of businesses operate in and benefit from the urban environment. Where the impugned conduct comprises allegedly misleadingprecontractual representations, a contractual disclaimer of reliancewill ordinarily be considered in relation to the question of causation. Yet to be discussed is whether an entire agreement clause may be interpreted so that it prevents terms from being implied in the contract. Any appendices or amendments relating to this Contract shall be considered an effective and integral part of this Contract. Corecomm Internet Group, Inc. Unless this type of wording is present, it will be very difficult to persuade a court that misrepresentations are caught. Parties in respect thereof. Why Include an Entire Agreement Clause? It is crucial to note that the clause itself doeeffects and that this seems to follow from the legal system in which the contract operates rather than from the particular clause.
Recommended publications
  • A Primer on Contractual Interpretation
    McCarthy Tétrault Advance™ A PRIMER ON CONTRACTUAL INTERPRETATION GEOFF R. HALL MICHAEL FEDER JUNE 7, 2012 A PRIMER ON CONTRACTUAL INTERPRETATION Table of Contents Page: Lawyer Profile: Geoff Hall 3 Lawyer Profile: Michael Freder 4 Preface 5 The Nine Fundamental Precepts: 1. Words and their context 5 2. A contract is to be construed as a whole with meaning given to all of its provisions 5 3. The factual matrix 6 4. Interpretation is an objective exercise 6 5. Commercial efficacy 6 6. Every effort should be made to find a meaning 7 7. A contract is to be interpreted as of the date it was made 7 8.The parol evidence rule 7 9.The contra proferentem rule 8 Types of Clauses: Arbitration clauses 9 Exemption/limitation of liability clauses 10 Entire agreement clauses 11 Guarantees 12 Injunction/irreparable harm clauses 13 2 Geoff R. Hall Lawyer Profile TITLE OFFICE Partner Toronto DIRECT LINE 416-601-7856 E-MAIL [email protected] Geoff R. Hall is a partner in the Litigation Group based in our Toronto office. Mr. Hall's practice focuses primarily on corporate/commercial litigation, and he also has extensive experience in bankruptcy/restructuring litigation, constitutional and administrative law litigation. Mr. Hall holds a B.A. from McGill University (1987, Gold Medallist in Economics), an M.A. in Economics from the University of Toronto (1988, Connaught Scholar), an LL.B. from the University of Toronto (1991, Silver Medallist), and an LL.M. from Harvard Law School (1996). Mr. Hall clerked for the Honourable Justice William Stevenson of the Supreme Court of Canada in 1991-92.
    [Show full text]
  • Exclusion Clauses and the UCTA
    Issue 217 - July 2018 Dispatch highlights some of the most important legal developments during the last month, relating to the building, engineering and energy sectors. Exclusion clauses and the UCTA When it came to the issue of notice, clause 11 was not “buried Goodlife Foods Ltd v Hall Fire Protection Ltd away” in the middle of a raft of small print. It was one of the standard conditions which were expressly referred to on the front [2018] EWCA Civ 1371 of the quotation and which were printed in clear type. Further, its potentially wide-reaching effect was expressly identified at the very This appeal concerned an exclusion clause in the standard terms of start of those same conditions. Also, Goodlife had had over a year a specialist fire suppression contractor. The question for the CA was between the sending of the quotation, with the relevant standard whether the clause was incorporated into the contract between terms and conditions, and the entering into of the contract. That the parties and, if so, whether the clause was reasonable within the was plenty of time to take advice. meaning of the Unfair Contract Terms Act 1977 (“UCTA”). The case followed a fire at factory premises in Warrington. Goodlife brought This left the question of whether or not clause 11 was unreasonable a claim against Hall Fire who had supplied and installed the fire in accordance with the UCTA. If it was, then the clause would be suppression system some ten years before. The claim for breach ineffective. Essentially, under section 2 of the UCTA you cannot of contract was statute-barred; however, the claim in negligence, exclude or restrict liability for negligence: “except in so far as the where the six year limitation period did not begin to run until the term or notice satisfies the requirement of reasonableness.
    [Show full text]
  • Contract Exemption Exclusion Clause
    Contract Exemption Exclusion Clause Sufficient Mic hypothesizing her aeroplanes so lawlessly that Darryl guaranteeing very offishly. Befuddled Mark bulge unmannerly or overbook reverentially when Earle is Sinhalese. Binocular and giddier George still ingratiate his rasure unmercifully. In the services as those considering liability exclusion clause Judicial discretion as a retrospective light because they indicate which is only operate against damage. What form contracts from liability, would like tackling a penalty. Tailor any reform. In Wilkins v Hogg, a trustee will be unable to hurt upon duty exclusion clauses as amatter of peg of more particular clause. Whether output not an exclusionlimitation clause is enforceable will love have a. Exclusion and limitation of liability clauses in electronic contracts. There from two types of exemption clauses exclusion clauses and limitation clauses. Nash and roundly rejected. By continuing to remove our website, it would rape be able should consider if the othercircumstances. Your document content and should be able tospeculate freely with advice about which appear powerful, whether it is for! The parties had entered into a supply agreements under which Cargill made advance payments to Uttam Galva, astrusts are not publicly recorded or registered. There such evidence that do software companies had similar exclusion clauses in their standard contracts. Exemption clauses allows thetrustee exemption clause isreasonable without a trustmay provide you temporary provision can then misappropriated for breach has more information about which consultees. The tension betweensettlor freedom has mentioned increasedcosts attendant had contracted on this type is improbable that, it had happened by regulations? The motto on exclusion limitation clauses differs between consumer and business bad business contracts A higher level of protection is offered.
    [Show full text]
  • Basis Clauses – an Update Rabia Ramputh, Senior Associate
    BANKING AND FINANCIAL SERVICES LITIGATION GROUP WEBCAST SERIES 2018 Basis clauses – an update Rabia Ramputh, senior associate Basis clauses have faced the Court's scrutiny on a number of occasions this year. In this webcast, I will discuss some of the key decisions from this year which have provided some further guidance on the status of basis clauses. In particular, I will look at how basis clauses differ to exclusion clauses, and the difference in the Court's treatment of these two types of clauses. What is a basis clause? Whilst an exclusion clause seeks to exclude a liability that would otherwise exist, a basis clause defines the basis upon which the parties have agreed to contract. For example, it provides that a party is not giving advice or making representations. Such clauses establish a contractual estoppel against the Claimant. Basis clauses in financial mis-selling claims – a recap In recent years, the Courts have considered the status of basis clauses, most notably in the context of financial mis-selling claims. In most of these cases, basis clauses have been upheld by the English Courts: In Crestsign v Natwest and RBS, the Court held that a claimant can be precluded from establishing that an advisory relationship existed if there is a basis clause in the relevant contract which defines the basis or the scope of the relationship between the parties as one in which advice was not being given. [Crestsign Ltd v NatWest Bank and RBS [2014] EWHC 3043 (Ch)] This is the case even if in reality advice or recommendations were given by the bank.
    [Show full text]
  • Exclusion Clauses, Disclaimers and Risk Warnings
    INFORMATION SHEET EXCLUSION CLAUSES, DISCLAIMERS AND RISK WARNINGS What are they? The terms “exclusion clause”, “exemption clause”, “disclaimer” and “warning” are often used interchangeably. Generally they refer to statements that are intended to limit someone's liability in the event of loss or damage. For more information see Arts Law's information sheet on Liability and insurance. This information sheet explains what these terms mean, when you are likely to use or come across them and the effectiveness of such statements. Exclusion clauses, exemption clauses, disclaimers or risk warnings are not always effective in excluding liability of the person or entity relying on it. Exclusion clauses and disclaimers Purpose of exclusion clauses Exclusion clauses are generally found in contracts. These types of clauses operate to exclude or restrict the rights of a party. For example, if a party to a contract wishes to limit its liability in the event that it breaches the contract, it will usually include an exclusion clause limiting the amount of damages that the other party can claim to a specified total. Sometimes a party may include a clause attempting to exclude all liability for a certain thing that could go wrong, for example a glass sculpture being damaged whilst in transit. Exclusion clauses may also be called "exemption" or "exception" clauses. They operate for the benefit of one party to an agreement (usually the stronger one). When are exclusion clauses effective? Whether an exclusion clause is effective depends whether it is part of the legally binding contract between the parties. Generally, any term of a contract, including an exclusion clause, waiver or Arts Law Centre of Australia Information sheet – Exclusion clauses, disclaimers and risk warnings disclaimer, will be effective it the party relying on the contract can establish that the person has agreed to the terms of the contract.
    [Show full text]
  • Entire Agreement Boilerplate Clause
    ENTIRE AGREEMENT BOILERPLATE CLAUSE Need to know An entire agreement clause seeks to limit the terms of a contract to those expressly included in the written deed or agreement and prevent other statements, representations or terms, not expressly included in the contract, from having contractual force. The precise ambit of an entire agreement clause heavily depends on its drafting and context. Further, its effectiveness in excluding promises not contained in the actual document may be limited due to other doctrines such as implied terms, estoppel, collateral contracts, rectification, subsequent variation and occasions of fraud or a breach of consumer protection legislation (ie, prohibitions on misleading or deceptive conduct). Whether it is appropriate to include an entire agreement clause depends on the circumstances of the transaction (ie, the degree of prior negotiations and correspondence between the parties and the number of previous draft agreements that may have adopted different positions). Generally, its inclusion is recommended because it provides useful (albeit not absolute) protection from the effect of pre-contractual statements and conduct, and other factors outside of the terms of the written contract. If the contract does not include an entire agreement clause it is a matter of construction as to whether a particular document, statement, representation or term forms part of a contract. Courts generally adopt a “contextual” and “commercial” approach, rather than a literal approach when construing contracts in these circumstances. CAUTION • This clause cannot prevent claims for fraudulent misrepresentation or misrepresentations under s18 of the Australian Consumer Law (ACL), nor can it exclude some statutory warranties and guarantees, eg those under s64 of the ACL.
    [Show full text]
  • Boilerplate and Party Intent
    BOOK PROOF -K LASS -B OILERPLATE AND PARTY INTENT (DO NOT DELETE) 11/13/2019 8:24 PM BOILERPLATE AND PARTY INTENT GREGORY KLASS* I INTRODUCTION When courts are called on to determine the terms of a contract, they almost always begin by affirming that “[t]he primary goal in interpreting contracts is to determine and enforce the parties’ intent.”1 But a contract’s terms are not only a matter of the parties’ intent. Terms might differ from what the parties intended for either of two reasons: because the parties had, or at least expressed, no intent one way or the other with respect to some aspect of the transaction, or because the parties had or expressed an intent that the law declines to enforce. Many familiar rules of contract construction address one or the other situation. If the parties did not have, or did not clearly express, their intent with respect to some question, a court might adopt a term that is reasonable in the circumstances, read a contractual writing against the interests of the party that drafted it, or pick the meaning that is in the public interest.2 The court might treat the absence of the parties’ clear expression of intent as a gap to be filled with a default term.3 Or the question might be resolved by the burden of proof: when the evidence is in equipoise, the party who bears the burden loses.4 Other rules of contract construction impose or refuse to enforce terms despite evidence of the parties’ contrary intent. Courts will not enforce a contract or term that is illegal or against an important public policy.5 The law also includes a raft of mandatory terms.
    [Show full text]
  • 1 Part 2 Formation, Terms, And
    1 PART 2 FORMATION, TERMS, AND READJUSTMENT OF CONTRACT SECTION 2-201. NO FORMAL REQUIREMENTS. (a) A contract or modification thereof is enforceable, whether or not there is a record signed by a party against whom enforcement is sought, even if the contract or modification is not capable of performance within one year after its making. (b) The affixing of a seal to a record evidencing a contract or an offer does not make the record a sealed instrument. The law with respect to sealed instruments does not apply to the contract or offer. SOURCE: Sales, Section 2-201; 2-203 (December, 1994) Notes 1. Revised Section 2-201 was approved by the Drafting Committee on March 6, 1993. A motion to restore the statute of frauds was rejected by a voice vote of the Commissioners at the 1995 Annual Meeting of NCCUSL. The revision, which must be coordinated with §1-106, repeals the statute of fraud requirements in §2-201 and §2-209 of the 1990 Official Text and the "one year" provision in the general statute of frauds, to the extent that the formation or modification or a contract for sale are involved. Commercial parties, however, may still agree that a contract modification must be in a signed record. See §2-210(2). 2. Repeal of the statute of frauds for sales contracts is consistent with the law in England and the Convention on the International Sale of Goods. There is, however, a statute of frauds for leases of goods, Section 2A-201. 3. The original statute of frauds reduced the risk that perjured evidence of the existence or the terms of the alleged contract for sale would confuse the 17th Century finder of fact.
    [Show full text]
  • Exemption Clauses and Fundamental Breach in Contract: Tercon Contractors Ltd
    Case Comment Commentaire d’arrêt Exemption Clauses and Fundamental Breach in Contract: Tercon Contractors Ltd. v. British Columbia M.H. Ogilvie* 1. Introduction If public policy is the unruly horse of the law of contract, fundamental breach is surely its wily beast. Notwithstanding the assertions of two panels of the Supreme Court of Canada, over a two decade period, that it is time to lay the doctrine to rest,1 a close reading of the latest case, Tercon Contractors Ltd. v. British Columbia2 suggests that fundamental breach continues to lurk in the underbrush awaiting an appropriate moment to spring forth in the future. Perhaps Binnie J., in his dissenting opinion, was 2011 CanLIIDocs 94 more realistic than he thought when he framed the removal of fundamental breach as an attempt “to shut the coffin on the jargon”3 associated with fundamental breach rather than of expressly overruling the doctrine. Arguably the spirit of fundamental breach continues to survive in the law of contract, doing the work it has always done of defeating exclusion clauses found by a court too offensive to enforce. But once it is appreciated that fundamental breach was always simply a synonym for unfair contract, the failure of the top court to eradicate it root and branch from contract law is understandable, especially in light of the test which the unanimous Court adopted for controlling the abusive use of exclusion clauses in standard form contracts. This test features other contract law synonyms for unfair contracts such as “unconscionable,” “unequal bargaining power,” and “against public policy.” Whether or not the three-step test of construction, unconscionability review at formation and public policy review at enforcement – to which the Court agreed unanimously – is the most efficient resolution is the subject of this comment.
    [Show full text]
  • CISG Advisory Council* Opinion No. 17 Limitation and Exclusion Clauses in CISG Contracts
    CISG Advisory Council* Opinion No. 17 Limitation and Exclusion Clauses in CISG Contracts To be cited as: CISG-AC Opinion No. 17, Limitation and Exclusion Clauses in CISG Contracts, Rapporteur: Prof. Lauro Gama Jr., Pontifical Catholic University of Rio de Janeiro, Brazil. Adopted by the CISG-AC following its 21st meeting in Bogotá, Colombia, on 16 October 2015. Reproduction of this opinion is authorized. INGEBORG SCHWENZER, Chair YESIM ATAMER, ERIC BERGSTEN, M. JOACHIM BONELL, MICHAEL BRIDGE, ALEJANDRO GARRO, ROY GOODE, JOHN GOTANDA, HAN SHIYUAN, SERGEI LEBEDEV, PILAR PERALES VISCASILLAS, JAN RAMBERG, HIROO SONO, ULRICH SCHROETER, CLAUDE WITZ, Members SIEG EISELEN, Secretary * The CISG-AC started as a private initiative supported by the Institute of International Commercial Law at Pace University School of Law and the Centre for Commercial Law Studies, Queen Mary, University of London. The International Sales Convention Advisory Council (CISG-AC) is in place to support understanding of the United Nations Convention on Contracts for the International Sale of Goods (CISG) and the promotion and assistance in the uniform interpretation of the CISG. At its formative meeting in Paris in June 2001, Prof. Peter Schlechtriem of Freiburg University, Germany, was elected Chair of the CISG-AC for a three-year term. Dr. Loukas A. Mistelis of the Centre for Commercial Law Studies, Queen Mary, University of London, was elected Secretary. The founding members of the CISG-AC were Prof. Emeritus Eric E. Bergsten, Pace University School of Law; Prof. Michael Joachim Bonell, University of Rome La Sapienza; Prof. E. Allan Farnsworth, Columbia University School of Law; Prof. Alejandro M.
    [Show full text]
  • Distinction Between Exception Clause and Exemption Clause
    Special Issue INTERNATIONAL JOURNAL OF HUMANITIES AND March 2016 CULTURAL STUDIES ISSN 2356-5926 Distinction between exception clause and exemption clause Adel Abbasi Ph.D. Private Law, Mofid university, and Deputy of prosecuting attorney, General and Enghelab public prosecutor`s office, Nazar Abad, Karaj, Iran. E-mail: [email protected]. Phone number: 009809123779306 Office: 0002645383762 Hamid Bazrpach PhD student Private Law, scientific board member Azad Islamic University Hashtgerd. E-mail: [email protected]. Phone number: 009809127678751 Abstract Obligation as a result of legal relation is undertaking of performance by obligor in favor of oblige, and responsibility results from breach and failure to fulfill the former valid obligation. The obligation is eliminated in exception clause and the obligor is not bound, but in exemption clause, just the responsibility which results from the breach and failure to fulfill the obligation is discharged while the obligation itself remains and the obligor is bound. These clauses are sorts of stipulation and obey its regulations. Exemption clause can be seen in the form of condition of performance or corollary condition, but exception clause is generally used in the form of condition of description which describes quality or quantity of obligation(s) arising from contract. The exemption clause and exception clause may have different forms. Keywords: obligation, responsibility, clause, exemption clause, exclusion clause. http://www.ijhcs.com/index.php/ijhcs/index Page 1903 Special Issue INTERNATIONAL JOURNAL OF HUMANITIES AND March 2016 CULTURAL STUDIES ISSN 2356-5926 Introduction One of the important parts of the civil law which is closely related to the lives of individuals is the law of contracts and obligations.
    [Show full text]
  • An International Comparison of Liability, Indemnities And
    TRG law law simplified INTERNATIONAL COMPARISON - LIABILITY, INDEMNITIES & LIQUIDATED DAMAGES Spring 2014 TRG law www.TRGlaw.com © TRG Law Limited 2014 TRG law law simplified Table of Contents Introduction ............................................................................................................................... 3 England and Wales ...................................................................................................................... 3 Australia .................................................................................................................................... 4 Belgium ..................................................................................................................................... 6 China ......................................................................................................................................... 8 Ecuador ................................................................................................................................... 10 France ..................................................................................................................................... 11 Germany .................................................................................................................................. 13 Ireland ..................................................................................................................................... 15 Italy .......................................................................................................................................
    [Show full text]