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Articles 121 - 123 of 123
Full-Text Articles in European Law
The Warranty Of Quality In Sale Of Goods Under The Perspective Of The American And French Law, Renaud Baguenault De Puchesse
The Warranty Of Quality In Sale Of Goods Under The Perspective Of The American And French Law, Renaud Baguenault De Puchesse
LLM Theses and Essays
While the United States’ common law system is characterized by diversity due to each state having its own set of rules, in certain areas there are nationwide legislative attempts of unification and standardization. One such attempt is the adoption of the Uniform Commercial Code which governs the sale of goods law in the United States. The French civil law system generally differs greatly from the American system in that it is primarily based upon statutes and codes. However, the American Uniform Commercial Code and the French Civil Code provide tangible, comparable bases to assess similarities and differences between American and …
International Concurrent Jurisdiction: Dealing With The Possibility Of Parallel Proceedings In The Courts Of More Than One Country, Bernd U. Graf
International Concurrent Jurisdiction: Dealing With The Possibility Of Parallel Proceedings In The Courts Of More Than One Country, Bernd U. Graf
LLM Theses and Essays
This thesis will examine how legal systems deal with the phenomenon of multiple assumptions of jurisdiction over the same dispute. We will first look at public international law rules on jurisdiction, regulating (or not regulating) conflicting states' interests, which will give only modest guidance. In view of those rules, the subsequent chapters will deal with various national laws relating to the possibility of parallel proceedings in the courts of more than one country, and thus the possibility of the emergence of conflicting orders or judgments.
The Role Of Efficiency Justifications In U.S.-American And West German Merger Control Law: A Comparison, Christian Westerhausen
The Role Of Efficiency Justifications In U.S.-American And West German Merger Control Law: A Comparison, Christian Westerhausen
LLM Theses and Essays
When merger control laws first emerged in the United States and West Germany in the early 1900s, some businessmen and economists argued that the efficiency of businesses was impeded by antimerger laws. They contended that only very large businesses could realize significant efficiencies, be internationally competitive, and attain technological progress. This paper analyzes the role that these efficiency arguments had on the laws in West Germany and the United States, respectively. German law mainly upheld the idea that preservation of competition was most important for business efficiency, but also included a provision that firms could put forward the social desirability …