8 Article 16 of the Rome I Regulation, entitled ‘Multiple liability’, provides:

Article 16 of the Rome I Regulation, entitled ‘Multiple liability’, provides:

Germany submits that Article 16 of Rome I, concerning multiple liability claims, applies.

Article 20 (concerning multiple liability of debtors) of that regulation therefore determines the applicable law in the action for recourse between the insurers.

Article 16 of Rome I preserves continuity of applicable law where there is multiple liability in the context of contractual obligations.