Question juridique clé
Whether the public law appeal was admissible against the appellate court's determination of applicable foreign law and the factual criteria for a German establishment.
Solution extraite
The challenge was inadmissible insofar as it attacked the application of federal conflict-of-law rules and the related factual assessment; such arguments had to be raised by reform appeal.
Motifs extraits
Because the complaint concerned application of Art. 117 PILA and thus federal law, it was barred by the absolute subsidiarity of public law appeal under Art. 84(2) OG, especially since a parallel reform appeal had been filed.