Recovering Attorneys’ Fees under CISG: An Interpretation of Article 74*

The subject of this essay is the recoverability of attorneys’ fees under the United Nations Convention on Contracts for the International Sale of Goods (CISG). The recoverability of attorneys’ fees under the CISG is one of the most controversial issues in contemporary CISG jurisprudence. Domestic courts, international arbitral tribunals, and domestic arbitral tribunals diverge as to why, how, and whether to award attorneys’ fees under CISG governed contracts.