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Articles 1 - 30 of 31
Full-Text Articles in Comparative and Foreign Law
Refugee Crisis In Germany And The Right To A Subsistence Minimum: Differences That Ought Not Be, Ulrike Davy
Refugee Crisis In Germany And The Right To A Subsistence Minimum: Differences That Ought Not Be, Ulrike Davy
Georgia Journal of International & Comparative Law
No abstract provided.
A Gateway Into The South?: The Effect Of The Uaw's Proposed Introduction Of European-Style Works Councils Into Collective Bargaining In The United States, Gregory Mark
Georgia Journal of International & Comparative Law
No abstract provided.
The Traditional View Of Public Policy And Ordre Public In Private International Law, Kent Murphy
The Traditional View Of Public Policy And Ordre Public In Private International Law, Kent Murphy
Georgia Journal of International & Comparative Law
No abstract provided.
Book Review: Political Crime In Europe: A Comparative Study Of France, Germany And England. Barton L. Ingraham. University Of California-Berkeley Press, 1979., Albert M. Pearson Iii
Book Review: Political Crime In Europe: A Comparative Study Of France, Germany And England. Barton L. Ingraham. University Of California-Berkeley Press, 1979., Albert M. Pearson Iii
Georgia Journal of International & Comparative Law
No abstract provided.
The New Conflict Of Laws Code Provisions Of The Federal Republic Of Germany: Introductory Comment And Translation, Rainer Gildeggen, Jochen Langkeit
The New Conflict Of Laws Code Provisions Of The Federal Republic Of Germany: Introductory Comment And Translation, Rainer Gildeggen, Jochen Langkeit
Georgia Journal of International & Comparative Law
No abstract provided.
The Wood Pulp Case: The Application Of European Economic Community Competition Law To Foreign Based Undertakings, Evan Breibart
The Wood Pulp Case: The Application Of European Economic Community Competition Law To Foreign Based Undertakings, Evan Breibart
Georgia Journal of International & Comparative Law
No abstract provided.
Commercial Letters Of Confirmation In International Trade: Austrian, French, German And Swiss Law And Uniform Law Under The 1980 Sales Convention, Michael Esser
Georgia Journal of International & Comparative Law
No abstract provided.
Age Discrimination--Extraterritorial Application Of The Age Discrimination In Employment Act--Equal Employment Opportunity Commission Determines That A United States Corporation Operating In West Germany Is Subject To Suit Under The Age Discrimination In Employment Act--Employer's Defense Based On Compliance With West German Law Rejected, Chris Lauderdale
Georgia Journal of International & Comparative Law
No abstract provided.
Discrimination In Employment: Reflections On The European Community Experience With Particular Reference To The United Kingdom, Brian Bercusson
Discrimination In Employment: Reflections On The European Community Experience With Particular Reference To The United Kingdom, Brian Bercusson
Georgia Journal of International & Comparative Law
No abstract provided.
Discrimination In Employment In The Federal Republic Of Germany, Uschi Backes-Gellner, Bernd Frick
Discrimination In Employment In The Federal Republic Of Germany, Uschi Backes-Gellner, Bernd Frick
Georgia Journal of International & Comparative Law
No abstract provided.
German Reunification - The Privatization Of Socialist Property On East Germany's Path To Democracy, Michael J. Thomerson
German Reunification - The Privatization Of Socialist Property On East Germany's Path To Democracy, Michael J. Thomerson
Georgia Journal of International & Comparative Law
No abstract provided.
The Recognition And Enforcement Of Punitive Damage Awards In Germany: Recent Developments, Andre R. Fiebig
The Recognition And Enforcement Of Punitive Damage Awards In Germany: Recent Developments, Andre R. Fiebig
Georgia Journal of International & Comparative Law
No abstract provided.
Protecting Defamatory Fiction And Reader-Response Theory With Emphasis On The German Experience, Henry Ordower
Protecting Defamatory Fiction And Reader-Response Theory With Emphasis On The German Experience, Henry Ordower
Georgia Journal of International & Comparative Law
No abstract provided.
The Value Of Public-Notice Filing Under Uniform Commercial Code Article 9: A Comparison With The German Legal System Of Securities In Personal Property, Jens Hausmann Dr.
The Value Of Public-Notice Filing Under Uniform Commercial Code Article 9: A Comparison With The German Legal System Of Securities In Personal Property, Jens Hausmann Dr.
Georgia Journal of International & Comparative Law
No abstract provided.
Hitler's Ghosts: The Interplay Between International Organizations And Their Member States In Response To The Rise Of Neo-Nazism In Society And Government, Marjorie L. Morton
Hitler's Ghosts: The Interplay Between International Organizations And Their Member States In Response To The Rise Of Neo-Nazism In Society And Government, Marjorie L. Morton
Georgia Journal of International & Comparative Law
No abstract provided.
Freedom Of Religion In Public Schools In Germany And In The United States, Inke Muehlhoff
Freedom Of Religion In Public Schools In Germany And In The United States, Inke Muehlhoff
Georgia Journal of International & Comparative Law
No abstract provided.
A Comparison Of Corporate Taxation In The United States And Germany: Different Ways Up The Mountain, Walter D. Schwidetzky
A Comparison Of Corporate Taxation In The United States And Germany: Different Ways Up The Mountain, Walter D. Schwidetzky
Georgia Journal of International & Comparative Law
No abstract provided.
Balancing The First Amendment And Child Protection Goals In Legal Approaches To Restricting Children's Access To Violent Video Games: A Comparison Of Germany And The United States, Laura Tate Kagel
Georgia Journal of International & Comparative Law
No abstract provided.
A Comparative Study Of Monitoring Of Management In German And U.S. Corporations After Sarbanes-Oxley: Where Are The German Enrons, Worldcoms, And Tycos?, Florian Stamm
Georgia Journal of International & Comparative Law
No abstract provided.
The European Union, State-Sponsored Gambling, And Private Gambling Services: Time For Harmonization?, Matthew W. Mauldin
The European Union, State-Sponsored Gambling, And Private Gambling Services: Time For Harmonization?, Matthew W. Mauldin
Georgia Journal of International & Comparative Law
No abstract provided.
Germany And The U.S. Present: A Roadmap For Protecting State Sovereignty In The European Stability Mechanism, Matthew Gregory
Germany And The U.S. Present: A Roadmap For Protecting State Sovereignty In The European Stability Mechanism, Matthew Gregory
Georgia Journal of International & Comparative Law
No abstract provided.
Legalize It? -Osp And Peer-To-Peer Network Liability For Online Music Copyright Infringements In The United States And Germany, Christian Nils Jochen Engelhardt
Legalize It? -Osp And Peer-To-Peer Network Liability For Online Music Copyright Infringements In The United States And Germany, Christian Nils Jochen Engelhardt
LLM Theses and Essays
It may be useful to explain why a comparative approach was chosen. It is easy and comfortable to get caught up in one's own legal system and not look abroad. It is often difficult enough to understand and apply one’s own laws accurately and the study of a foreign legal system may seem an effort too great. Yet, this reluctance to look beyond the familiar is fatal to legal development and improvement since entirely new ideas are rare in the field of law and the main source of change and new approaches is borrowing from another legal system. If one …
Comparison Between Freedom Of Religion In Germany And In The United States In General And The Treatment Of The Church Of Scientology Specifically, Wolfgang Eichele
Comparison Between Freedom Of Religion In Germany And In The United States In General And The Treatment Of The Church Of Scientology Specifically, Wolfgang Eichele
LLM Theses and Essays
The thesis first gives background information about the general development of fundamental rights in both Germany and the United States and specifically the freedom of religion. The analysis discusses in particular freedom of religion granted by Article 4 of the Basic Law in Germany and the religious clauses of the First Amendment of the American Constitution. In the first conclusion, the differences in the interpretations of the religious clauses both in Germany and the United States will be stated. These differences will then be illustrated by a discussion on the Church of Scientology through its basic facts, history, ideas, and …
Freedom Of Religion In Public Schools In Germany And In The United States, Inke Muehlhoff
Freedom Of Religion In Public Schools In Germany And In The United States, Inke Muehlhoff
LLM Theses and Essays
Unfortunately, in terms of religions, the strict neutrality is almost impossible to reach and most countries that have adopted such a principle still face religious conflicts. However, these conflicts have shifted from armed conflicts to legal conflicts and battles of words, which offer at least a more peaceful way to fight. One major battleground for these religious conflicts concerns the role of religion in the public school system. That battleground is the subject of this thesis. The discussion of how religion should be treated in the public school system will be based on a comparison between Germany and the United …
The Liability Of The Automobile And Motorcycle Manufacturers And Their Suppliers For Defective Products In The United States Compared To Germany, Daniel Karl Robyn
The Liability Of The Automobile And Motorcycle Manufacturers And Their Suppliers For Defective Products In The United States Compared To Germany, Daniel Karl Robyn
LLM Theses and Essays
This thesis deals with the lability of automobile and motorcycle manufacturers, as well as their suppliers, in situations where a defective product causes a harmful event. Specifically, it compares the product liability laws of the Federal Republic of Germany to those of the United States of America. Before entering into the details of legal doctrine, the introductory note provides background information on the social and economic aspects of automobile use in those two countries. Next, Chapter I describes the liability regime governing claims against German motor vehicle manufacturers and their suppliers. Chapter II focuses on the comparable law in the …
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
Double Taxation - Treatment Of Corporate Earnings Under American And German Law, Roland Schmidt
LLM Theses and Essays
This thesis is going to describe the different ways the United States and Germany deal with the problem of double taxation in the legal context of corporate distributions to its shareholders in the form of dividends. Tax law is particularly one of the areas of laws that are subject to frequent and often substantial changes. This is true for the German as well as for the U.S. tax laws. Since some of the issues being discussed in the United States today in connection with the corporate tax law are similar if not identical to the issues discussed in Germany before …
International Arbitration And Procedures To Enforce Awards In The Relationship Between The United States And Germany, Michael Kronenburg
International Arbitration And Procedures To Enforce Awards In The Relationship Between The United States And Germany, Michael Kronenburg
LLM Theses and Essays
Arbitration has long been regarded as a process that combines finality of decision with speed, low expense, and flexibility in solving problems. For these reasons, arbitration is often favored over litigation for dispute resolution. Particularly in international cases, a businessman may avoid litigation in a foreign country for various reasons: he may be unfamiliar with the proceedings; he may be afraid to find a “forum hostile” because of the different legal and cultural background of the judges; and he may wish to avoid the uncertainty concerning the law arising from the contract. Arbitration proceedings have been held constitutional by the …
Forum Shopping In Products Liability Actions: A Comparison Between The United States, France And Germany, Lothar W. Baum
Forum Shopping In Products Liability Actions: A Comparison Between The United States, France And Germany, Lothar W. Baum
LLM Theses and Essays
The goal of this research is to state the current situation concerning products liability in the United States, the Federal Republic of Germany and more briefly, France and to compare the different systems. Emphasis will be given to the substantive laws, in particular to the new EC Directive and its adoption in the Federal Republic of Germany. Also, it will discuss the current German law, since this will be valid for all claims initiated before the enactment of the new ProdHaftG. Further, based on the previous analysis, it will be shown where a consumer is in the most favorable position …
Per Se Legality Of Vertical Restraints: Contested In America -- Not Debated In Germany: Search For Reasons And Comparison, Rainer F. Hildebrandt
Per Se Legality Of Vertical Restraints: Contested In America -- Not Debated In Germany: Search For Reasons And Comparison, Rainer F. Hildebrandt
LLM Theses and Essays
The approach towards vertical restraints depends heavily on the outcome of the "battle for the soul of antitrust". Therefore, to make the implications of the dispute more comprehensible, this study necessarily has to prefer to the basics of antitrust policy such as legislative history and political underpinnings. The second chapter addresses the underlying values of American and German antitrust laws and compares the concepts chosen to protect these values. Based on these foundations, chapter three evaluates resale price maintenance. In chapter four, the Supreme Court's judgment in Business Electronics Corp. v. Sharp Electronics Corp. is analyzed according to the GWB …
Planning Under The National Environmental Policy Act: The Use Of Environmental Impact Statements In Agency Decisionmaking, Ralf Marxen
LLM Theses and Essays
This article focuses on Environmental Impact Statements (EIS) as part of the Federal National Environmental Policy Act and will therefore not deal with the different State Environmental Policy Acts (SEPA) or their relation to and interaction with Federal legislation. Furthermore, this article will focus upon those issues that are of special relevancy to the possible adoption of EISs into the German legal system. The article will also address cost-benefit issues related to the EIS process. Part VIII (judicial review) will only concentrate on the judicial review of administrative action concerning environmental planning through EISs.