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29. Alternatively, depending on the forum, its conflict rules, and any choices of subsidiary laws made by the parties, supranational rules such as the UNIDROIT Principles might apply. Throughout this Article, reference will be to recourse to "domestic law,' for the sake of convenience, although I do not discount the possible application of supranational laws.

30. See Gyula Eörsi, General Provisions , in INTERNATIONAL SALES: THE UNITED NATIONS CONVENTION ON CONTRACTS FOR THE INTERNATIONAL SALE OF GOODS 2-01, 2-04 (Nina M. Galston Hans Smit eds., 1984) (stating that "no recourse to national law should be admitted in interpretation" (citation omitted)); Bonell, supra note 22, at 74-75 (discouraging resort to domestic law or principles in interpreting the CISG based on the CISG's "international character" and ultimate aim of global uniformity).

31. The internal interpretative method has also been referred to as the "implied 'interpretative paradigm.'" Kilian, supra note 5, at 229 (citation omitted).

32. See Ferrari, supra note 15, at 21 ("Indeed, unless it has been decided ... that the CISG applies at all, neither the Convention's substantive provisions, nor its provisions on interpretation ... can be used to solve any dispute.").

33. UNCITRAL Digest of Case Law on the United Nations Convention on the International Sale of Goods (Article 7) 4, U.N. Doc. No. A/CN.9/SER.C/DIGEST/CISG/7 (2004) [hereinafter UNCITRAL Digest of Case Law (Article 7) ]; Bonell, supra note 22, at 83; see also Ferrari, supra note 25, at 158, 171 (noting the obligatory nature of resort to private international law where general principles do not lead to a solution); Joseph Lookofsky, Walking the Article 7(2) Tightrope Between CISG and Domestic Law , 25 J.L. COM. 87, 90 (2006) [hereinafter Lookofsky, Tightrope ] (mentioning that only non-CISG rules and principles can address external matters); JOSEPH LOOKOFSKY, UNDERSTANDING THE CISG IN THE USA 20 (1995) [hereinafter LOOKOFSKY, UNDERSTANDING] (same); Hartnell, supra note 6, at 18 (arguing that in the case of questions of validity, domestic law would apply since the CISG does not address the issue).

34. CISG, supra note 1, arts. 4-5; Ferrari, supra note 14, at 340.

35. E.g. , UNCITRAL Digest of Case Law on the United Nations Convention on the International Sale of Goods (Article 4) 5-6, U.N. Doc A/CN.9/SER.C/DIGEST/CISG/4 (2004).

36. CISG, supra note 1, art. 7(1).

37. See Alejandro Garro, Reconciliation of Legal Traditions in the U.N. Convention on Contracts for the International Sale of Goods , 23 INT'L LAW. 443, 443 (1989); Disa Sim, The Scope and Application of Good Faith in the Vienna Convention on Contracts for the International Sale of Goods (Sept. 2001), < >, at 4, 5-6 (discussing the inclusion of representation of common law, civil law, socialist, and capitalist countries in drafting committees); Kazuaki Sono, The Vienna Sales Convention: History and Perspective , in INTERNATIONAL SALE OF GOODS: DUBROVNIK LECTURES 1, 3 (Petar �arevic Paul Volken eds., 1986) [hereinafter DUBROVNIK LECTURES] (noting that responses to UNCITRAL questionnaires indicated the lack of "global representation" at their creation as one reason that the ULIS and ULF did not succeed).

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EU leaders choose Juncker to lead the future of the Union

Meeting in the European Council on 26-27 June, EU leaders decided on their candidate for President of the European Commission. They also discussed a strategic agenda for the EU, the peace plan proposal in Ukraine and congratulated Greece on the main achievements of its presidency.

The European Council adopted the decision proposing to the European Parliament Jean Claude Juncker as President of the European Commission after a formal vote by qualified majority.

The decision follows the extensive discussions Herman Van Rompuy had with the main European Parliament parties and member states' representatives to identify the best possible candidate for the job .

The European Council decided to meet again on 16 July to discuss the nominations for the other top EU positions .

At a specific event in Ypres on 26 June, to mark the centenary of the outbreak of World War I, EU leaders discussed the future of the EU, its priorities and purpose in the years to come .

They agreed on a strategic agenda which focuses on 5 main objectives and the means to achieve them:

Leaders repeated their commitment to reforms and fiscal consolidation, but also their will to carry out the investments needed for the future. To balance fiscal discipline with the need to support growth, the EU's existing fiscal framework offers possibilities which should be used.

President Van Rompuy said: "We are all committed to the Stability and Growth Pact and that it is a matter of making best use of the flexibility that is built into the existing Stability and Growth Pact rules ."

"We are all committed to the Stability and Growth Pact and that it is a matter of making best use of the flexibility that is built into the existing Stability and Growth Pact rules", saidPresident Van Rompuy.

EU leaders welcomed President Poroshenko's peace plan . But the European Council regrets that the cease-fire has not led to the full cessation of military hostilities.

Regarding sanctions , the European Council is committed to reconvene at any time to adopt further significant restrictive measures if a detailed list of concrete steps are not taken by Russia and the separatists by Monday 30 June :

In summary, while on the face the -ms-high-contrast media feature may look useful for authors, in practice the information that an author can get from querying this feature is limited (in the case of -ms-high-contrast:active ) and only applicable in some very specific situations (for -ms-high-contrast:white-on-black and -ms-high-contrast:black-on-white ).

About Patrick H. Lauke

Patrick works as Senior Accessibility Engineer for The Paciello Group. He is a member of the W3C Pointer Events Working Group and W3C Touch Events Community Group . In a previous life he was a Web Evangelist in the Developer Relations team at Opera, and before that he worked as Web Editor for a large UK university for nearly 10 years. Patrick has been involved in the discourse around Web Standards and Accessibility since 2001, actively speaking at conferences and participating in initiatives such as the (now discontinued) Trask Addy Leather Bootie GCZm3nkXw
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The more I’ve played around with high contrast, the more I am convinced that the best way to think of it is as a “custom colors” media query or “accessible colors” media query. Basically, a warning that the user is over-riding your color scheme. It could be used to turn off custom colors or graphical effects, but should not lead to any assumptions about what color scheme is preferred. If you’re going to use it to colors, such as in an SVG or canvas graphic, I think the best approach is to use the CSS System Colors keywords ( Crocs Bistro Gingham NcPLSfRx78
) to match the colors that the browser will automatically apply to the rest of your page. The following CSS system colors are updated in MS Edge Firefox to match the corresponding colors in the Windows High Contrast Mode (WHCM) dialog:

There is no CSS named color that corresponds to the Hyperlinks text color in WHCM. MS Edge applies the WHCM to hyperlinks regardless, but Firefox uses the default blue color. CSS System Colors test case with SVG color swatches for each color: Steve Madden Poet PJXoiAG

Unfortunately, Firefox does not respond to the (-ms-high-contrast) media query, and does not have their own -moz- media query for custom color modes. If you’re using the media query to fix color schemes or images, they won’t see any of your adjustments.


“It could be used to turn off custom colors or graphical effects” however – if we’re talking about the HTML/CSS side here – these are already turned off /overridden by virtue of the high contrast mode itself being active.

CSS system colours were brought up in discussions leading up to this blog post. Though officially deprecated in CSS 3 (something which I incidentally questioned all the way back in 2005 ), these do indeed still work in IE and Edge.


Greg Whitworth has written up a response to this blog post: How to use -ms-high-contrast Some excellent information about and the use of the (deprecated, though still working) CSS system color identifiers. And the main take-away for me is: use the media query as a high-level indication that the user is indeed in high contrast mode, and if needed use CSS system colors to ensure certain colors are applied.

But I still stand by the fact that / are mostly pointless since they only apply to two very specific scenarios.


For , I guess the reason for them is that these are the two most popular schemes among the users of High Contrast theme. You can provide optimised image resources for these users. My personal blog uses them extensively. For most screenshots exhibited in my entries, I provide four versions — non HC, BoW, WoB, and a fall back version. Usually the fall back version is generated by taking the screen shot of HC#1. But recently I have been using my own scheme.

Having available implies you are using a browser that should provide the colours to you, therefore it is safe to use CSS system colours.

The same logic applies to Windows app development — the XAML framework supports themed dictionaries, which includes 6 themes – light, dark, BoWHC, WoBHC, CustomHC and AnyHC. Most of the time one only has to use light / dark + AnyHC.

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