What law applies to a claim for damages for breach of a company director’s equitable duty of care? This question raises difficulties in the choice of law involving equitable doctrines and the borderlands in the choice of law categories for obligations and corporations. The question is compounded by the potential overlapping sources of a director’s duty of care in domestic law: statute, tort, contract, and equity. This gives rise to another difficulty: should the claimant be allowed to pick and choose from as many choice of law rules as there are such causes of action, even though the individual causes of action may be different domestic conceptualizations of a single duty arising from the facts? The answer to this last question depends in part on the related question whether the Rome Convention

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