Joshua Karton is an Assistant Professor in the Faculty of Law at Queen's University in Kingston, Ontario, Canada, where he has taught since 2009. A graduate of Yale (BA 2001) and Columbia Law School (JD 2005), he is a member of the New York Bar. He practiced as an associate in the litigation/arbitration group at Cleary Gottlieb Steen & Hamilton LLP in New York before pursuing his doctoral studies at Cambridge, from which he graduated in 2011 with a PhD in law. This book is based on his PhD thesis, which was supervised by James Crawford and Louise Merrett. Professor Karton was awarded the International & Comparative Law Quarterly Young Scholar Prize for an article based on an earlier version of Chapter Six of this book.