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Fraud And Injunctive Relief In International Standby Letter Of Credit Transactions: A Comparative Study, Dirk H. Mahler
Fraud And Injunctive Relief In International Standby Letter Of Credit Transactions: A Comparative Study, Dirk H. Mahler
LLM Theses and Essays
This study attempts to compare the various concepts which have been developed under U.S. and German law, focusing in particular the interpretation of fraud and the prerequisites for injunctive relief. Comparative analysis of case law, statutory provisions and corresponding commentaries will illustrate that although evolved out of different legal backgrounds the results show only minor deviations, a phenomenon which might support the hypothesis that instruments developed by practitioners to serve international commercial needs tend to give birth to uniform internationalized legal treatment.
The Proper Law Of Business Torts, Georg H. Kutschelis
The Proper Law Of Business Torts, Georg H. Kutschelis
LLM Theses and Essays
This paper's purpose is to define as clearly as possible the law that best fits business torts which bring into play two or more systems of law. The definition of "tort" being another field in which scholarly activity has not led to a consensus, and the qualification of "business tort" considerably adding to the vagueness of the subject, it is sufficient here to state that the thrust of this analysis is on choice-of-law problems. But in order to test the resulting rule or method cases will be selected both from the frequent tort cases arising out of accidents and from …