Introduction

The major goal of this research is to see how successful or unsuccessful an electronic bill of lading has been in replacing its paper counterpart, with an emphasis on global electronic commerce legislation and/or practises. This article will discuss the traditional paper bill of lading, its advantages and pitfalls. The article will focus its discussion around the challenge of negotiating the electronic BoL and the technical efforts at resolving the challenges like the registry system. Lastly this paper will conclude if electronic BoL have been a success.

Bills of Lading (BoL)

A BoL is a legal document that specifies the kind, amount, and destination of goods being transported by a carrier. If the buyer has not been selected, the BoL might be written out to the seller's order. Seller becomes shipper when a carriage contract is established. The BoL is made out to the buyer if known. Putting the buyer's name on the BoL from the start makes him the consignee. If the BoL is made out to the buyer, he is the endorsee. In cases and legislation, the consignee or endorsee of the BoL is always referred to as the third party. BoL serves three purposes. First, it proves the carriage contract. It is also a receipt for sent items. This includes weight, identifying markings, and shipping condition. BoL also acts as a document or title.  

On the BoL are the ports of shipping and discharge. Type and amount of sent commodities are also listed, for example 500 tonnes of wheat. The BoL will list any identifying markings on bags or containers. It also specifies the shipping condition. The things were received and sent in excellent shape, for example. The BoL includes the issue and shipping dates. This is the day all cargo has passed the ship's rail. A buyer will check this when they acquire the documentation to verify the date is within the specified shipping term. Agents sign and stamp this document and the BoL terms appear on the reverse.

Advantages of the paper BoL

Since paper bills of lading have been used for centuries, there are many precedents, manuals, and legal rulings on their uses and ramifications. This strengthens the clarity of the law on paper bills of lading and the trust of legal and financial professionals when offering advice on the law and practises pertaining to their usage. Also, confident and simple endorsement and delivery of the paper BoL allows transfer goods rights.[1] The paper BoL becomes trustworthy collateral for documentary credit transactions, boosting international trade finance.[2] Large-scale use of paper BoL has led to worldwide consistency in laws and procedures. Hague, Hague-Visby, and Hamburg Rules are examples. Furthermore, papers BoL’s are within the knowledge and skills of many consumers, especially in less developed nations with poor technological infrastructure.[3]

The disadvantages of paper BoL

Why are electronic transport papers emerging? Lower expenses, less fraud and corruption, and products arriving before the BoL are all possible reasons.[4] Paper BoL’s do not match current business realities[5] because they are insecure, complicated, and costly to use in shipping transactions, and errors cause delays. Ship operators rely on indemnities since paper invoices seldom arrive before oil cargo voyages. Banks that lend credits have trouble securing actual security, thus they use standby letters of credit.[6] Paper BoL account for 10 to 15% of worldwide shipping costs. Since the paper BoL is issued in a set of three originals, fabricating any of the originals to establish or negotiate goods rights is likely. Inaccurate and inadequate details on the paper BoL are another drawback.[7]

Negotiating the Electronic BoL

The BoL is negotiable[8] as long as the transferee or endorsee acknowledges all influencing equities. This distinguishes the BoL from other instruments of title, such as bills of exchange, which are completely negotiable, enabling transferees to accept them free from faults in transferors' titles, so long as they obtained them for value and without knowledge of such shortcomings. BoL transferees cannot acquire better titles than transferors.[9] For a BoL to be considered an instrument of title under common law, it must be a bearer or order BoL, since a straight bill renders goods deliverable to a specified consignee without transferability wording or other negating components.[10]

Electronic BoL “negotiability” causes the most problems.[11] Existing laws and economic methods for negotiating bills of lading are purely paper-based, therefore manual authentication and physical ownership of the original bill vested title to the commodities.[12] Several solutions have been developed to meet the challenges of electronic BoL, including negotiability. These approaches include a third-party or central registration system, passwords, biometrics, physical feature recognition, and private and public key cryptography.[13] Vieira argues negotiable instruments may only be created by legislation or commercial usage.[14] No law allows parties to a carriage contract to transfer goods rights or title through electronic exchanges or texts.[15] Laryea is hopeful that electronic contracts will become tradable.[16] Electronic BoL’s are not yet negotiable due to marine parties' unwillingness to embrace existing electronic business processes.[17]

Hague-Visby, the Hamburg and the Rotterdam Rules

International attempts to integrate and harmonise private law have been precise, coordinated, and responsive to accommodate the use of electronic communications and messages in contractual transactions relating to carriage of goods by sea.[18] However The Hague and Hague-Visby Rules are created to connote tangibility and do not enable extension of terminology like "document", "writing", and "signature" to digital documentation or communication.[19] The Hamburg Rules, however, have several clauses that may be regarded as allowing electronic papers or BoL so long as there are no national laws barring their use. It is not clear if electronic signatures authorised under the foregoing provision may be for the electronic BoL. The Hamburg Rules do not directly address an electronic bill's negotiability or document-of-title status. The Rotterdam Rules[20] are more clear and straightforward about electronic communications and records. The convention employs more neutral words like “transport document and “electronic transport record”.[21] Article 1(15) of the Rotterdam Rules allows electronic bills of lading to be negotiable.

UNCITRAL Model Law on Electronic Commerce

UNCITRAL adopted the Model Law on Electronic Commerce (MLEC) on 12 June 1996.[22] It gives nations a model for harmonised legal regimes that support digital information transmission and storage, by ensuring functional parity, media neutrality, and legal recognition and enforcement for electronic documents and communications. It is voluntary and contracts may have its clauses. It comprises of two components. Part 1 covers electronic commerce, while Part 2 includes marine transit. The recognition and definition of Electronic Data Interchange (EDI) for Transport Documents under the MLEC[23] suits the electronic BoL effectively. Electronic invoices are available for further uses or references; therefore they meet Article 10 of the MLEC's validity and enforceability requirements. MLEC drafters wanted functional equality and media neutrality for electronic BoLs and communication. The MLEC, like other electronic commerce regimes, is written in generic terms to allow for future advances in information communication technology. Given the speed and consistency of information and communication technology, this is the ideal strategy.[24]

Comité Maritime International Rules

The Comité Maritime International (CMI) created Rules in 1990[25] to fix the SeaDocs system and deploy computerised BoLs in maritime freight operations.[26] CMI Rules outlined carriers' computerised BoL system. They are a regulatory framework or idea that requires parties to use electronic BoL in maritime transport contracts.[27] CMI Rules are not a system since they provide no institution or authority to control the issue, transmission, certification, and transfer of electronic bills generated within its framework.[28]

Under Article 3 of the CMI Rules, UNCID controls EDI if it does not violate the rules.[29] EDI must follow UN/EDIFACT unless the parties agree on another method.[30] The CMI Rules use electronic alerts, receipt messages, and private keys to indicate ownership or control.[31] Carrier sends "receipt message" to shipper's electronic address once parties agree to use electronic BoL under CMI Rules and after receiving goods from shipper.[32] The message must include the shipper's name, a description of the goods, the date and place of receipt, and the carrier's terms and conditions of carriage.[33] This is like freight invoices. Once the shipper confirms receipt to the carrier, it may act on the message. Private Key holders may transfer control or title of commodities like paper BoL holders.[34]

UK Law

Under English law, any rights and obligations under a BoL issued are controlled largely by Carriage of Goods by Sea Act (COGSA) 1992. To be negotiable, an electronic BoL must first be a document of title under English law or another legal framework. Transferees of BoL did not gain rights or responsibilities under English law until the BoL Act 1855. Goldby believes the Factors Act, 1889, Sections 8-10 and Sale of Goods Act 1979, Sections 24, 25(1), and 47, might accommodate the electronic BoL.[35] Even though an electronic BoL is a document of title under English law, it cannot transfer title to goods subject to a maritime transportation contract since it is not a COGSA-recognized transport document. COGSA does not refer to a paper that cannot be transferred by endorsement or delivery without endorsement as a bearer bill.[36]  The Secretary of State may apply COGSA to electronic BoL via regulations.[37] However this has never been done.

In order to negotiate an electronic BoL under English law, a private legal framework, such as the Bolero Rulebook, must be established and used. With each instance of resale of the goods, a new contract of carriage will be created via the process of novation and attornment, whereby the new contract replaces the previous contract on the same conditions between the carrier and the new holder. COGSA does not therefore apply to electronic BoL. Thus, in order to achieve a negotiation of an electronic BoL under English law as it presently stands, it will be necessary to set up and apply a private legal framework such as the Bolero Rulebook in which there will be a new contract of carriage with every instance of re-sale of the goods by the mechanism of novation and attornment by which the new contract replaces the old contract on the same terms between the carrier and the new holder. [38]

Technical Efforts

Building a successful electronic commerce infrastructure will need coordination among record managers, IT professionals, and digital forensics specialists.[39] Information and communication professionals should be equally concerned with the social and legal elements of workplace computer usage as with hardware and software, say King and Stanley.[40] Industry practitioners have devised a variety of technological techniques to avoid or mitigate the problems of electronic commerce, namely electronic duplication of the paper BoL. This paper will focus on the registry system.

The Registry System

To successfully replicate the third traditional function of serving as a document of title in an electronic environment, the adopted electronic alternative method must be able to determine, who the electronic bill holder is, so that a data message (already used in transferring rights or obligations) cannot be used inconsistently with such rights or obligations.[41] This is "a guarantee of uniqueness" under Article 17(3) of the MLEC or "exclusive control of electronic transport data" under the Rotterdam Rules. The document-of-title function of the paper BoL has only been effectively duplicated in the electronic environment by the registry system.[42]At each issuance or transfer, the electronic BoL holder's name is recorded in a registry.[43]

SeaDocs

SeaDocs was the first significant attempt to dematerialise an electronic BoL via the central register system.[44] Chase Manhattan Bank and the International Association of Independent Tanker Owners initiated the SeaDocs project.[45] The SeaDocs system was intended as a bridge between paper documentation and a completely electronic system. When the bank received the original paper BoL, it telexed users.[46] Under SeaDocs, the carrier issued a paper BoL that SeaDocs Ltd retained as a mutual agent and registrar of BoL agreements.[47] SeaDocs could negotiate the BoL while the items were in transit and provide the original to the consignee.[48] After obtaining the original paper from the shipper, an electronic test code or key code was supplied. The shipper was obliged to electronically inform SeaDocs of its desire to negotiate the bill and to furnish the buyer/endorsee with a part of the key code.[49] SeaDocs would verify the information and register the buyer/endorsee as the cargo's 'legal owner'.[50] The buyer/endorsee would get an electronic BoL to accept delivery at the port of discharge.[51]

Despite being legal and having no operational issues or high registration charges, the SeaDocs system failed due to a lack of commercial partners and banks.[52] The SeaDocs failed because: (1) commodity traders were unwilling to expose themselves to tax authorities and other competitors by recording their transactions in the SeaDocs' central registry; (2) cargo buyers were uncomfortable obtaining bills of lading from an entity designed to serve intermediaries and speculators; and (3) banks were uncomfortable with one of their competitors having exclusive control and access to the registry.

The SeaDocs fiasco shows that a registration monopoly may not be practical. A register must be available to any interested party and include tools that allow purchasers and lenders to easily verify whether an electronic BoL has encumbrances.[53] Dubovec believes that a consortium of banks or an independent operator, such as SWIFT, may gain greater support among traders.[54] The study showed that negotiable BoLs could be dematerialized via a central registry[55] and established the groundwork for further successful trials and/or endeavours such as the Bolero Project.

Bolero Project

The Bolero Project, with European Commission assistance, was founded in 1998[56] by the International Chamber of Commerce and is owned by the Through Transport Club and the Society for Worldwide Inter Bank Financial Telecommunications (SWIFT).[57] Bolero is the first successful electronic trade documentation project after SeaDocs and CMI Rules failed.[58]

Through the common law ideas of attornment and novation, the Bolero System has effectively accomplished negotiability of electronic BoL.[59] While novation entails the carrier terminating the previous contract with the previous holder and forming a new one with the new holder on the same terms, attornment is an undertaking by the carrier as the bailee of the goods to deliver the goods to the new “holder”,  giving the new holder constructive possession of the goods.[60] The contract of carriage, as well as the rights and liabilities arising from it, is transferred through novation and attornment, in which Bolero acts as the agent of the carrier, who, as a continuing party to the new contract, acknowledges the new holder's constructive possessory right over the goods.[61]

Rule 3.7 of the Bolero Rule Book permits reversion to a paper bill of lading, but it replicates all the functions of a typical paper BoL, especially the document-of-title role, and will gain favour as confidence in electronic transactions grows.[62] Subject to required international standards, UK law applies to Bolero bill of lading contracts, and UK courts have exclusive jurisdiction for Bolero Rule Book noncompliance.[63] Non-compliance with the Bolero Rule Book is not an exclusive jurisdiction.[64] As for choice of law, nothing in the Bolero Rule Book prohibits a parallel system of laws to realise contractual aim.[65]

ESS-Databridge

ESS-Databridge was created in 2003 to dematerialise conventional transport documentation.[66] The 2005-piloted ESS Databridge system launched in January 2010.[67] All platform users are bound by the ESS-Databridge Services and Users Agreement (DSUA).[68] CargoDocs allows ESS-Databridge members to issue and transmit electronic BoL.[69] ESS-Databridge does not utilise title registry, unlike Bolero.[70] Like the Bolero system, its services are exclusively available to members bound by the DSUA, and electronic bills of lading are negotiable by novation, assignment, or attornment.[71] DSUA is controlled by UK law, but when the contract of carriage is governed by US law, transfer of title under DSUA is governed by New York law, including the New York Uniform Commercial Code (UCC) and the Uniform Electronic Transactions Act 1999 (UETA).[72]

ESS-Databridge allows users to "sign", "issue", "amend", and "endorse" electronic bills of lading.[73] One person at a time may access the electronic record for exclusive control.[74] Once an electronic BOL or document is endorsed, the endorser loses possession of the original and maintains only a copy designated for recordkeeping.[75] Other electronic documents may be submitted with the endorsement.[76] The ESS-Databridge electronic BoL replicates the conventional paper BoL on the computer screen, increasing familiarity and acceptance of the CargoDocs service's electronic documentation.[77]

The ESS-Databridge paradigm is a considerable advance over the prior comparable attempts in many areas. If needed, customs may convert the electronic BoL to paper. It includes eUCP and has a clear obligation and responsibility for eRisks, eFailure, and eCrimes.[78] ESS's client base, which includes trade businesses, banks, carriers, freight forwarders, surveyors, and ships' agents, rises 20% a month.[79] Many ESS-Databridge customers are in emerging and developing nations, especially Latin America. If the right conditions are met, more underdeveloped nations may use CargoDocs.[80]

Conclusion

In conclusion how successful have electronic BoL been? Well the BoL is the most crucial maritime shipping document. Electronically replicating the receipt for items received for transportation or actually sent and the contract of carriage is easy. Sea waybills and delivery orders may also be converted to electronic format. The BoL’s third role as the document of title for delivered goods cannot be completed electronically under UK law. Under the UK’s legislation, electronic bill negotiation requires attornment and novation. Electronic BoL issues go beyond negotiability. Electronic bills are non-negotiable, but writing, originality, and signature criteria are universal to all electronic papers. Electronic documents as evidence for dispute resolution also come under this umbrella.

Marek Dubovec says these registry systems failed because they could not replicate the negotiability function of paper bills of lading. He also suggests paper document collateral security. Any electronic BoL need a trusted registry.[81] Stakeholders have undertaken a variety of initiatives to address the issues of the electronic BoL, including the SeaDocs project, public and private key encryption, and digital signatures. In legal systems like the UK where there is no formal accommodation for electronic BoL, a third-party or private registry system might be used to recreate the document-of-title function in an electronic context. Let us wait and see.

Annotated Bibliography

Carr, I., “UNCITRAL and Electronic Signatures-A Light Touch at Harmonisation” (2002) 1(2) Journal of International Commercial Law, 141-159. Discusses how the international community sought to replace handwritten signatures with electronic ones. Electronic signatures may be signs, digital photos, biometric scans, or even fingerprints.

Charles, C, E-Commerce Law for Business Managers (Canterbury, Financial World Publishing, 2002). This is a small-business legal guide on creating a commercial website. Security, corporate identification, and service offering are discussed. The book is a legal guide for online businesspeople.

Chukwuma, R. F. S. C. “Can the functions of a paper bill of lading be replicated by electronic bill of lading” (2013) 3(8) Public Policy and Administration Research, 101-108. This author explores the legal and technical barriers of reproducing paper bills as an electronic record of title. They argue technical bill of lading negotiation involves technological and legal infrastructure. Chukwuma favours legislation to handle electronic documentation, especially electronic bills of lading, to maintain media neutrality and functional equivalence.

Delmedico, Amedeo “EDI bills of lading: Beyond negotiability” (2003) 1(1) Hertfordshire Law Journal, 95-100. This article promotes paperless BoL and analyses three prominent candidates, from Chase Manhattan Bank's Seaborne Trade Documentation System (SEADOCS) Project to the newest Bolero Project, a turning point in the evolution of e-commerce documentation.

Dubovec, Marek, “The problems and possibilities for using electronic bills of lading as collateral" (2005) 23 Ariz. J. Int'l & Comp. L., 437. According to him, electronic bill of lading negotiability requires effective technological and legal infrastructure.

Goldby, Miriam. "Electronic bills of lading and central registries: What is holding back progress?."  (2008) 17(2) Information & Communications Technology Law 125-149. This article investigates why electronic bills of lading aren't extensively adopted in international business years after BOLERO's creation. It explains why international trade hasn't embraced electronic equivalents.

Goldby, Miriam, Electronic documents in maritime trade: law and practice, (Oxford University Press, 2013). The author believes the Factors Act, 1889, Sections 8-10 and Sale of Goods Act 1979, Sections 24, 25(1), and 47, might accommodate the electronic bill of lading.

Goldby, Miriam, "Legislating to facilitate the use of electronic transferable records: A case study" (UNCITRAL Colloquium on Electronic Commerce 2011). The author gave instances of how prospective future centralised systems may significantly extend this field.

Kindred, HM “Trading Internationally by Electronic Bills of Lading” (1992) 7 Banking & Finance Law Review 265. The writers look at the legal and technical challenges of reproducing the functions of traditional paper bills in an electronic setting. 

King, Roger, and Carolyn Stanley, "Ensuring court admissibility of computer-generated records" ACM Transactions on Information Systems (1985) 3(4) Transactions on Office Information Systems, 398-412. A approach for maximising the admissibility of computer-generated documents in U.S. courts is explained. This strategy is for people switching to automated office practises and those with highly computerised enterprises.

Laryea, Emmanuel, Paperless Trade: Oppertunities, Challenges and Solutions. Vol. 1. (Kluwer Law International BV, 2002). The authors investigate the legal and technical challenges to reproducing paper bills as an electronic record of title. They argue technical bill of lading negotiation involves technological and legal infrastructure.

Marusic, Miran, “A Gateway to Electronic Transport Documentation in International Trade: The Rotterdam Rules in Perspective”, (2012) Master Thesis, University of Lund. This thesis described and analysed ETD convention provisions. This thesis discusses how the Rotterdam Rules may affect electronic transport document deployment.

Mason, Stephen, and Daniel Seng. Electronic evidence, (University of London Press, 2017). This is a comprehensive explanation of electronic evidence written by a group of professionals in the area.

Ritter, Jeffrey B., and Judith Y. Gliniecki, “International Electronic Commerce and Administrative Law: The need for harmonized national reforms” (1992) 6 Harv. JL & Tech., 263. They advocate the change from traditional paper based business practice. They argue that the electronic commerce is now viable and foreseeable change and argue for unified changes across the globe.

Sheppard, Anthony F., Luciana Duranti, and Corinne M. Rogers, “Electronic records and the law of evidence in Canada: the uniform electronic evidence act twelve years later” (2010) 70 The Journal of the Association of Canadian Archivists, 95-124. Twelve years after its passage, they analyse UEEA's competence to manage digital records. Facing constantly changing technology, the authors feel electronic records cannot be accounted for by simple legislative changes.

Svensson, B.,”Electronic Bill of Lading” (LLM Thesis, Lund University Faculty of Law, 2010) [unpublished]. This thesis discusses the problems of computerised bills of lading in international commerce. They may improve the environment, reduce paperwork costs, and simplify contractual procedures.

Vieira, A.C, Electronic Bills of Lading (LLM Thesis, University of Nottingham School of Law, 1999) [unpublished]. In his dissertation he argues, negotiable instruments are not created at will, but must be a result of either statutory recognition or mercantile usage.

Yiannopoulos, AAN, ed, Ocean Bills of Lading: Traditional Forms, Substitutes, and EDI Systems (The Hague: Kluwer Law International, 1995). This paper, which is a compilation of findings from the XIVth International Congress of Comparative Law in Athens in 1994, sheds light on the legal and technological issues that the EDI system and electronic bills of lading confront in various countries.

Footnotes

[1] AAN Yiannopoulos, “General Report” in AN Yiannopoulos ed, Ocean Bills of Lading: Traditional Forms, Substitutes, and EDI Systems (The Hague: Kluwer Law International, 1995) 3 at 38-39

[2] Ibid.

[3] Chukwuma, R. F. S. C. “Can the functions of a paper bill of lading be replicated by electronic bill of lading” (2013) 3(8) Public Policy and Administration Research, 101-108

[4] Svensson, B., Electronic Bill of Lading (LLM Thesis, Lund University Faculty of Law, 2010) [unpublished]

[5] Delmedico, Amedeo “EDI bills of lading: Beyond negotiability” (2003) 1(1) Hertfordshire Law Journal, 95-100

[6] AAN Yiannopoulos (n 1)

[7] Ibid.

[8] Barber v Meyerstein (1870) LR 4 HL 317

[9] Sheppard, Anthony F., Luciana Duranti, and Corinne M. Rogers, “Electronic records and the law of evidence in Canada: the uniform electronic evidence act twelve years later” (2010) 70 Archivaria, 95-124

[10] Ibid.

[11] Yiannopoulos, AAN, (n 1)

[12] Laryea, Emmanuel, Paperless Trade: Oppertunities, Challenges and Solutions. Vol. 1. (Kluwer Law International BV, 2002)

[13] Mason, Stephen, and Daniel Seng, Electronic evidence, (University of London Press, 2017)

[14] Vieira, A.C, Electronic Bills of Lading (LLM Thesis, University of Nottingham School of Law, 1999) [unpublished] at 8.

[15] Ritter, Jeffrey B., and Judith Y. Gliniecki, “International Electronic Commerce and Administrative Law: The need for harmonized national reforms” (1992) 6 Harv. JL & Tech., 263

[16] Laryea (n 12)

[17] Ritter (n 15)

[18] Ibid.

[19] Dubovec, Marek, “The problems and possibilities for using electronic bills of lading as collateral" (2005) 23 Ariz. J. Int'l & Comp. L., 437

[20] The Convention on Contracts for the International Carriage of Goods Wholly or Partly by Sea 11 December 2008, 63 UNTS 122

[21] Article 17(3)

[22] UNCITRAL, Model Law on Electronic Commerce, GA Res 51/162, GAOR 51st sess, 85th plen mtg,

UN Doc A/Res/51/162 (1996)

[23] Article 2(b)

[24] Carr, I., “UNCITRAL and Electronic Signatures-A Light Touch at Harmonisation” (2002) 1(2) Journal of International Commercial Law, 141-159

[25] Comité Maritime International Rules for Electronic Bills of Lading 1990 

[26] Laryea (n 12)

[27] Ibid.

[28] Ibid.

[29] Kindred, HM “Trading Internationally by Electronic Bills of Lading” (1992) 7 Banking & Finance Law Review 265 at 272

[30] Ibid.

[31] Laryea (n 12)

[32] CMI Rule 4(a)

[33] CMI Rule 4(b)

[34] Laryea (n 12)

[35] Goldby, Miriam, Electronic documents in maritime trade: law and practice, (Oxford University Press, 2013)

[36] s.1(2)(a) COGSA 1992

[37] s.1(5) COGSA 1992

[38] Goldby, Miriam, "Legislating to facilitate the use of electronic transferable records: A case study" (UNCITRAL Colloquium on Electronic Commerce 2011)

[39] Sheppard (n 9)

[40] King, Roger, and Carolyn Stanley, "Ensuring court admissibility of computer-generated records" ACM Transactions on Information Systems (1985) 3(4) Transactions on Office Information Systems, 398-412

[41] Goldby, Miriam, "Electronic bills of lading and central registries: What is holding back progress?" (2008) 17(2) Information & Communications Technology Law 125-149 at 126

[42] Ibid.

[43] Ibid.

[44] Dubovec (n 19)

[45] Delmedico (n 5)

[46] Dubovec (n 19)

[47] AAN Yiannopoulos (n 1)

[48] Ibid.

[49] Ibid.

[50] Delmedico (n 5)

[51] Ibid.

[52] AAN Yiannopoulos (n 1)

[53] Dubovec (n 19)

[54] Ibid.

[55] Delmedico (n 5)

[56] Laryea (n 12)

[57] Ibid.

[58] Ibid.

[59] Goldby (n 38)

[60] Ibid.

[61] Ibid.

[62] Goldby (n 35)

[63] Delmedico (n 5)

[64] Ibid.

[65] Ibid.

[66] Goldby (n 35)

[67] Ibid.

[68] Ibid.

[69] Ibid.

[70] Marusic, Miran, “A Gateway to Electronic Transport Documentation in International Trade: The Rotterdam Rules in Perspective”, (2012) Master Thesis, University of Lund

[71] Charles, C, E-Commerce Law for Business Managers (Canterbury, Financial World Publishing, 2002)

[72] Ibid

[73] Goldby (n 35)

[74] Goldby (n 38)

[75] Goldby (n 35)

[76] Marusic (n 70)

[77] Ibid.

[78] Ibid.

[79] Goldby (n 35)

[80] Ibid.

[81] Dubovec (n 19)