Questão jurídica principal
Whether the Federal Court could hear the appeal despite the parties' reliance on German law
Decisão extraída
The court held that the parties' express reliance on German law, together with the contract's performance links to Germany, excluded federal review under Art. 56 OG.
Fundamentação extraída
Where parties before the cantonal courts agree that foreign law governs, that choice is generally respected; here, price payment and delivery were tied to Germany, and the same German law also governed the counterclaims.