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Comparative and Foreign Law Commons

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2007

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Articles 1 - 30 of 294

Full-Text Articles in Comparative and Foreign Law

Towards A New General Comment On Article 20 Of The Iccpr: Exploring The Common Ground Between Freedom Of Expression And Freedom Of Religion Through The Concept Of Freedom From Vilification: The Danish Cartoons Case, Ahmad Ali Sharief Dec 2007

Towards A New General Comment On Article 20 Of The Iccpr: Exploring The Common Ground Between Freedom Of Expression And Freedom Of Religion Through The Concept Of Freedom From Vilification: The Danish Cartoons Case, Ahmad Ali Sharief

Archived Theses and Dissertations

No abstract provided.


Deal Or No Deal: Reinterpreting The Fcc's Foreign Ownership Rules For A Fair Game, Cindy J. Cho Dec 2007

Deal Or No Deal: Reinterpreting The Fcc's Foreign Ownership Rules For A Fair Game, Cindy J. Cho

Federal Communications Law Journal

With the changing racial and linguistic composition of the American market and the emerging strength of the Mexican market, American broadcast companies are facing a new competitive playing field.. Section 310 of the Communications Act of 1934 ("Act") establishes the guidelines for when a foreign national is eligible to apply for a broadcast license from the FCC. The FCC currently interprets these limits on foreign ownership very leniently, favoring a policy of deregulation in an attempt to further open up the United States market. This Note argues that once foreign nationals have cleared the hurdle of § 310's foreign ownership …


Tax Treaty Treatment Of Royalty Payments From Low-Income Countries: A Comparison Of Canada And Australia’S Policies, Kim Brooks Dec 2007

Tax Treaty Treatment Of Royalty Payments From Low-Income Countries: A Comparison Of Canada And Australia’S Policies, Kim Brooks

Articles, Book Chapters, & Popular Press

The proposal made in this paper is a modest one: that high-income countries should further the cause of reducing global inequality by ensuring that in their tax treaties with low-income countries they do not usurp needed revenues by reducing low-income countries' ability to collect tax on income with a source in the low-income country. This argument is made in the specific context of the taxation of royalty payments, which present one of the most extreme examples of high-income countries unfairly confiscating revenues that appropriately belong to their low-income treaty partners. The Organisation for Economic Co-operation and Development (OECD) model tax …


Japanese Prefectural Scapegoats In The Constitutional Landscape: Protecting Children From Violent Video Games In The Name Of Public Welfare, Susan Minamizono Nov 2007

Japanese Prefectural Scapegoats In The Constitutional Landscape: Protecting Children From Violent Video Games In The Name Of Public Welfare, Susan Minamizono

San Diego International Law Journal

Part I of this comment will examine the history and application of freedom of expression in Japanese case law and the evolution of the public welfare concept and its circumscribing effect on individual freedoms. Part II will explore the recent local regulatory efforts and the historical underpinnings for these laws that place restrictions on materials to children. Part III will compare the Japanese legislative endeavors with their American counterparts and highlight the reasons why United States laws will continue to be struck down by courts. Part IV will analyze the response of the video game industry to the onslaught of …


Net Neutrality: An International Policy For The United States, Frederick W. Pfister Nov 2007

Net Neutrality: An International Policy For The United States, Frederick W. Pfister

San Diego International Law Journal

Consider this scenario: Alex and John still are avid video game players and play hours a day, each connecting from the same town through different ISPs. However, since it is a peak Internet traffic time, it may be difficult for them to play. While Alex has the "Diamond" package from his ISP that ensures he has guaranteed high-bandwidth connection, John's ISP does not offer anything other than regular residential service. John must compete with everyone else in his local area for bandwidth, including a few who constantly watch high-definition video-on-demand and subsequently constrain bandwidth for other users. Would it not …


Silenced: The Search For A Legally Accountable Censor And Why Sanitization Of The Broadcast Airwaves Is Monopolization, Matthew S. Schneider Nov 2007

Silenced: The Search For A Legally Accountable Censor And Why Sanitization Of The Broadcast Airwaves Is Monopolization, Matthew S. Schneider

Cardozo Law Review

No abstract provided.


Using The Unidroit Principles To Fill Gaps In The Cisg, John Y. Gotanda Oct 2007

Using The Unidroit Principles To Fill Gaps In The Cisg, John Y. Gotanda

Working Paper Series

The United Nations Convention on the International Sale of Goods (CISG) sets forth only a basic framework for the recovery of damages, thereby giving a court of tribunal broad authority to determine an aggrieved party’s loss based on circumstances of the particular case. Unfortunately, the lack of specificity has resulted in much litigation, and seemingly conflicting results. To remedy this problem, some have argued that the gaps in the CISG damages provisions should be filled with the UNIDROIT Principles of International Commercial Contracts. In this paper, I argue that the gap-filling rules of CISG preclude the UNIDROIT Principles from being …


Litigating Canada-U.S. Transboundary Harm: International Lawmaking And The Threat Of Reciprocity, Shi-Ling Hsu Oct 2007

Litigating Canada-U.S. Transboundary Harm: International Lawmaking And The Threat Of Reciprocity, Shi-Ling Hsu

Scholarly Publications

No abstract provided.


Carter's Screed Against Israel, Alan M. Dershowitz Oct 2007

Carter's Screed Against Israel, Alan M. Dershowitz

University of Miami International and Comparative Law Review

No abstract provided.


Doctrinal Development In United States Arbitration: A Metamorphosis Of Paradigms Beyond Gregor Samsa's Imagination, Pedro J. Martinez-Fraga Oct 2007

Doctrinal Development In United States Arbitration: A Metamorphosis Of Paradigms Beyond Gregor Samsa's Imagination, Pedro J. Martinez-Fraga

University of Miami International and Comparative Law Review

No abstract provided.


Marbury V. Madison And Its Impact On Israeli Constitutional Law, Yoram Rabin, Arnon Gutfel Oct 2007

Marbury V. Madison And Its Impact On Israeli Constitutional Law, Yoram Rabin, Arnon Gutfel

University of Miami International and Comparative Law Review

No abstract provided.


Great Lakes, Weak Policy: The Great Lakes-St. Lawrence River Basin Sustainable Water Resources Agreement And Compact And Non-Regulation Of The Water "Products" Industry, Lauren Petrash Oct 2007

Great Lakes, Weak Policy: The Great Lakes-St. Lawrence River Basin Sustainable Water Resources Agreement And Compact And Non-Regulation Of The Water "Products" Industry, Lauren Petrash

University of Miami Inter-American Law Review

No abstract provided.


A Right To Leave But Nowhere To Go: Reconciling An Emigrant's Right To Leave With The Sovereign's Right To Exclude, Joy M. Purcell Oct 2007

A Right To Leave But Nowhere To Go: Reconciling An Emigrant's Right To Leave With The Sovereign's Right To Exclude, Joy M. Purcell

University of Miami Inter-American Law Review

No abstract provided.


Gender Discrimination Fuels Sex Selective Abortion: The Impact Of The Indian Supreme Court On The Implementation And Enforcement Of The Pndt Act, Kristi Lemoine, John Tanagho Oct 2007

Gender Discrimination Fuels Sex Selective Abortion: The Impact Of The Indian Supreme Court On The Implementation And Enforcement Of The Pndt Act, Kristi Lemoine, John Tanagho

University of Miami International and Comparative Law Review

No abstract provided.


Fighting Baseball Doping In Latin America: A Critical Analysis Of Major League Baseball's Drug Prevention And Treatment Program In The Dominican Republic And Venezuela, Arturo J. Marcano Guevara, David P. Fidler Oct 2007

Fighting Baseball Doping In Latin America: A Critical Analysis Of Major League Baseball's Drug Prevention And Treatment Program In The Dominican Republic And Venezuela, Arturo J. Marcano Guevara, David P. Fidler

University of Miami International and Comparative Law Review

No abstract provided.


Review And Oversight Of National Security Activities And Some Reflections On Canada's Arar Inquiry, Kent Roach Oct 2007

Review And Oversight Of National Security Activities And Some Reflections On Canada's Arar Inquiry, Kent Roach

Cardozo Law Review

No abstract provided.


Table Of Contents Oct 2007

Table Of Contents

University of Miami Inter-American Law Review

No abstract provided.


Wong Kim Ark And Sentencia Que Declara Constitucional La Ley General De Migración 285-04 In Comparative Perspective: Constitutional Interpretation, Jus Soli Principles, And Political Morality, Patrick J. Glen Oct 2007

Wong Kim Ark And Sentencia Que Declara Constitucional La Ley General De Migración 285-04 In Comparative Perspective: Constitutional Interpretation, Jus Soli Principles, And Political Morality, Patrick J. Glen

University of Miami Inter-American Law Review

No abstract provided.


The Insistent (And Unrelenting) Challenges Of Protecting Biodiversity In Brazil: Finding "The Law That Sticks", Colin Crawford, Guilherme Pignataro Oct 2007

The Insistent (And Unrelenting) Challenges Of Protecting Biodiversity In Brazil: Finding "The Law That Sticks", Colin Crawford, Guilherme Pignataro

University of Miami Inter-American Law Review

No abstract provided.


Executive Fraud And Canada's Regulation Of Executive Compensation, Bo James Howell Oct 2007

Executive Fraud And Canada's Regulation Of Executive Compensation, Bo James Howell

University of Miami Inter-American Law Review

No abstract provided.


The Legacy Of Colonialism: Law And Women's Rights In India, Varsha Chitnis, Danaya C. Wright Oct 2007

The Legacy Of Colonialism: Law And Women's Rights In India, Varsha Chitnis, Danaya C. Wright

UF Law Faculty Publications

The relationship between nineteenth century England and colonial India was complex in terms of negotiating the different constituencies that claimed an interest in the economic and moral development of the colonies. After India became subject to the sovereignty of the English Monarchy in 1858, its future became indelibly linked with that of England's, yet India's own unique history and culture meant that many of the reforms the colonialists set out to undertake worked out differently than they anticipated. In particular, the colonial ambition of civilizing the barbaric native Indian male underlay many of the legal reforms attempted in the nearly …


Corporate Social Accountability Standards In The Global Supply Chain: Resistance, Reconsideration, And Resolution In China, Li-Wen Lin Oct 2007

Corporate Social Accountability Standards In The Global Supply Chain: Resistance, Reconsideration, And Resolution In China, Li-Wen Lin

Cardozo Journal of International and Comparative Law

This Article provides a view on corporate social accountability standards from a Chinese perspective, a slightly different angle from that of legal scholars in the United States. The legal literature in the United States typically only focuses on the importance and effectiveness of corporate social accountability standards to regulate the conduct of multinational companies in the era of globalization. However, the views of the outsourced companies in the developing countries, on which the multinational companies impose the standards, have seldom received attention. This Article tries to fill this void by examining the situation in China. As shown in this Article, …


The Dysfunctional Progeny Of Eugenics: Autonomy Gone Awol, Matthew D. Martin Iii Oct 2007

The Dysfunctional Progeny Of Eugenics: Autonomy Gone Awol, Matthew D. Martin Iii

Cardozo Journal of International and Comparative Law

The article examines the ethical and legal implications of state-mandated sterilization, tracing its evolution from eugenic practices in the early 20th century to modern forms of reproductive control. It argues that such policies, whether justified by eugenics or population control, consistently violate human rights and raise significant moral concerns. The analysis critiques the Supreme Court's decision in Buck v. Bell as a landmark example of judicial endorsement of pseudoscientific discrimination, while also exploring contemporary issues like prenatal genetic testing and coercive family planning policies.


Can The Australian Model Be Applied To U.S. Moral Rights Legislation?, Joan Pattarozzi Oct 2007

Can The Australian Model Be Applied To U.S. Moral Rights Legislation?, Joan Pattarozzi

Cardozo Journal of International and Comparative Law

The note argues that the U.S. should adopt a more comprehensive framework for moral rights in copyright law, drawing inspiration from Australia's balanced approach, to better protect authors' personal and reputational interests while addressing concerns about market disruption and litigation. It highlights the U.S.'s current emphasis on economic rights, its limited implementation of moral rights under the Visual Artists Rights Act (VARA), and the potential for Australia's model to serve as a template for U.S. legislation.


A Final Plea For "Death With Dignity": A Proposal For The Modification And Approval Of The Assisted Dying For The Terminally Ill Bill In The United Kingdom, Lindsay Pfeffer Oct 2007

A Final Plea For "Death With Dignity": A Proposal For The Modification And Approval Of The Assisted Dying For The Terminally Ill Bill In The United Kingdom, Lindsay Pfeffer

Cardozo Journal of International and Comparative Law

Increasing respect for personal autonomy in health-related decision-making, major alterations in the assisted suicide laws of other European countries (especially Switzerland and the Netherlands), and the rising popularity of Swiss suicide clinics have introduced the need for the British legislature to reevaluate the United Kingdom's stance on assisted suicide and to adjust medical practices to contemporary social needs. The introduction and obstruction of a bill in the House of Lords for the legalization of physician-assisted suicide for terminally ill individuals has provoked opposition from the British medical community and serious concern on behalf of members of the government regarding the …


Scholarly Discourse And The Cementing Of Norms: The Case Of The Indian Supreme Court - And A Plea For Research, Jayanth K. Krishnan Oct 2007

Scholarly Discourse And The Cementing Of Norms: The Case Of The Indian Supreme Court - And A Plea For Research, Jayanth K. Krishnan

The Journal of Appellate Practice and Process

No abstract provided.


Information Collection Based On New Technologies: Comments On Protecting Liberty In An Age Of Terror, Olivier Dutheillet De Lamothe Oct 2007

Information Collection Based On New Technologies: Comments On Protecting Liberty In An Age Of Terror, Olivier Dutheillet De Lamothe

Cardozo Law Review

No abstract provided.


Has India Addressed Its Farmers' Woes? A Story Of Plant Protection Issues, Srividhya Ragavan, Jamie Mayer O'Shields Oct 2007

Has India Addressed Its Farmers' Woes? A Story Of Plant Protection Issues, Srividhya Ragavan, Jamie Mayer O'Shields

Faculty Scholarship

The paper examines issues relating to establishing breeders rights in developing nations by taking India as an example. At the outset, the paper examines the international obligations relating to protecting plant breeder’s rights by examining the requirements under Article 27.3 of the TRIPS agreement. In doing so, the paper examines analyzes what amounts to an effective sui generis system as required under TRIPS.

Further, the paper analyzes the constituents of the models currently touted by developed nations and outlined under the Union for Plant Variety Protection (UPOV, 1991) to determine the model’s ability to fulfill the TRIPS requirement. In determining …


From Federalism To Intersystemic Governance: The Changing Nature Of Modern Jurisdiction, Robert B. Ahdieh Oct 2007

From Federalism To Intersystemic Governance: The Changing Nature Of Modern Jurisdiction, Robert B. Ahdieh

Faculty Scholarship

At heart, this introductory essay aspires to encourage scholars who write in widely divergent areas, yet share a focus on the changing nature of jurisdiction, to engage one another more closely. From Jackson's study of "convergence, resistance, and engagement" among courts, Kingsbury's study of "global administrative law," and Bermann's analysis of "transatlantic regulatory cooperation," to Resnik's evaluation of "trans-local networks," Weiser's account of "cooperative federalism" in telecommunications law, and Thompson's concept of "collaborative corporate governance," a related set of questions is ultimately at stake: How ought we understand the reach of any given decision-maker's jurisdiction? What are the implications of …


Discrimination At Will: Job Security Protections And Equal Employment Opportunity In Conflict, Julie C. Suk Oct 2007

Discrimination At Will: Job Security Protections And Equal Employment Opportunity In Conflict, Julie C. Suk

Articles

The conventional wisdom amongst scholars and advocates of employment discrimination law is that the success of Title VII is significantly hampered by the enduring doctrine of employment at will. As long as employers have broad discretion to fire employees for any reason, no reason, or a bad reason, employers can easily get away with terminating or refusing to promote racial minorities and women as long as some credible nondiscriminatory reason, such as personal animosity, can be presented. This account feeds the widely accepted view that employment at will and the goals of Title VII, namely equal employment opportunity, are at …