1. The following excerpts and commentary were originally published in French in 4 JOURNAL DU DROIT INTERNATIONALE [J.D.I] 1005 (1992). Case No. 7153, International Chamber of Commerce, International Court of Arbitration (1992), commented on by Dominique Hascher, 4 J.D.I. 1007 (1992).

2. This Journal of Law & Commerce case translation was prepared by Vivian Curran, Legal Writing Instructor, University of Pittsburgh School of Law (B.A. University of Pennsylvania; Ph.D., J.D., Columbia University). Any reader who intends to rely on this case must consult the original text. All footnotes in the following material were supplied by the translator and did not appear in the original material.

3. Commentary by Dominique Hascher, Conseiller Général et Secrétaire Général Adjoint, International Court of Arbitration, International Chamber of Commerce, 4 J.D.I. at 1007, supra note 1.

4. DIP is the legal abbreviation for droit international public ("public international law") and for droit international privé ("private international law.").

5. The New Law of the International Sale of Goods.

6. International Markets.

7. The International Sale of Goods.

8. LGDJ is the legal abbreviation for Librairie Générale de Droit et de Jurisprudence.

9. U.N. Conference on Contracts for the International Sale of Goods, Final Act, U.N. Doc. A/Conf. 97/18 (1980) [hereinafter "CISG"], reprinted in S. Trcaty Doc. No. 98-9, 98th Cong., 1st Sess. and 17 INT'L LEGAL MAT. 668 (1980). Article 25 defines fundamental breach and Article 74 deals with the calculation of damages for breach of contract, without restricting its application to fundamental breaches.

10. "Interest Accruing From the Commencement of Actions, Compensatory Damages -- Interest and Punitive Damages Before the International Arbitrator."

11. Under French law, "domicile" is the place where a citizen has his or her principal establishment rather than actual residence. See CODE CIVIL, Domicile, art. 102-111 (edition of 1 January 1983); see also JEAN BALEYTE, ALEXANDRE KURGANSKY, CHRISTIAN LAROCHE, JACQUES SPINDLER, DICTIONNAIRE ÉCONOMIQUE JURIDIQUE (3d ed. 1992).