Effect of assignment
Before discussing the merits of the applicable provisions, one has to
be aware that the effect of assignment is twofold.
If the assignment falls within
the scope of the Convention, the Convention sets the rules, otherwise the
applicable national law prevails.
In other words, an assignment with no effect with respect to the Convention may be effective with respect to the applicable
national law.
As a general rule one can say that an assignment under the Convention becomes effective when registered with the International
Registry.
Only then shall the respective priority rules and enforcement
remedies apply