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Jurisdictional Theory "Made In Japan": Convergence Of U.S. And Continental European Approaches, Akihiro Hironaka
Jurisdictional Theory "Made In Japan": Convergence Of U.S. And Continental European Approaches, Akihiro Hironaka
Vanderbilt Journal of Transnational Law
Recent Japanese cases concerning international jurisdiction illustrate a convergence of two distinct legal approaches to the treatment of jurisdictional issue--a rule-based, inflexible approach in Continental European countries and a standard-based, flexible approach in the United States. Japan's unique framework, as explained in this Article, might provide a useful perspective to solve the difficult question currently imposed on the Hague Conference: How is it possible to achieve comprehensive harmonization of the jurisdictional systems of the world?