At present, three international conventions (one of which has been modified by many signatory states to produce a fourth regime), together with certain pre-existing national regimes, provide this entitlement to limit most types of private law liability arising in the ordinary course of the shipowner's activities. Limitation may be invoked by the shipowner in two principal ways: by way of a defence, or by commencing a limitation action, which latter normally involves constituting a limitation fund. Whether the shipowner should take the initiative and start a limitation action, or whether he or she should wait and use limitation as a defense, will depend on the choice of fora available. Significant differences among jurisdictions inevitably give rise to forum-shopping. In the course of this book's practical explanation and discussion of shipowners' rights to limit their liability, the authors consider how the conflict of laws rules of various jurisdictions...

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