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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 …
Free Movement Of Goods Within The Economic Community Of West African States (Ecowas): Comparisons With European Economic Community (Eec), Theophilus Fuseini-Bart
Free Movement Of Goods Within The Economic Community Of West African States (Ecowas): Comparisons With European Economic Community (Eec), Theophilus Fuseini-Bart
LLM Theses and Essays
The Treaty establishing the Economic Community of West African States (ECOWAS)is substantially the same as the European Economic Community Treaty although it is not a carbon copy. To understand the subject matter of free movement of goods within the ECOWAS vis a vis the European Communities it will be necessary to discuss the genesis of the two Communities. Also important to discuss are the membership, institutions, and aims and objectives of both ECOWAS and the European Communities (EC). This will not only give a glimpse of the two Communities, especially ECOWAS which is more or less an obscure one, but …
A Comparative Analysis Of Unfair Dismissal Law With Particular Reference To The Law As It Pertains To The South African Worker, Haydn T. Hillestad
A Comparative Analysis Of Unfair Dismissal Law With Particular Reference To The Law As It Pertains To The South African Worker, Haydn T. Hillestad
LLM Theses and Essays
This paper will begin with an investigation of the activity of the International Labour Organization (ILO) in domestic employment laws. Using this as a yardstick, a comparative analysis of the unfair dismissal laws of the United States and some foreign countries (mainly Western European) will be undertaken. Finally, the issue will be addressed in the South African context. An assessment will be made of the relative quality of the protection afforded workers in South Africa and, using conclusions reached from the comparative study, the validity of calls for a general unfair dismissal statute in the country will be considered.
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.