4.1 CISG

• Governs sales of goods between parties, unless they opt out
• supersedes UCC
• Only governs formation, rights and obligations

• Art 1:
• both parties must be contracting State or
• Choice of law that says to apply CISG
• (UK is not a contracting State)

• The place of business of both parties to the K are each in diff States
• both States are K parties

Art 8: look at parties common understanding or intent, where understanding or intent of parties diverge and one party knew or could have been aware of the other party's intent -- might be able to avoid last shot doctrine

Art 96: if contracting State has so declared, a party can use Art 12 to declare writing required of local law states taht and the party has a princ. place of business in that state