Full Description
Now in its second edition, and with significant updates and new material, Gilles Cuniberti's innovative textbook offers a comparative treatment of private international law, a field of great importance in an increasingly globalized world. Written by a leading voice in the field, and using a text and cases approach, this text systematically presents and compares civil law and common law approaches to issues primarily within the United Kingdom, United States, France and the EU, as well as offering additional updated insights into rules applicable in other jurisdictions such as Japan, China and Germany.
Key features of the second edition include:
New topics covered in the fields of jurisdiction and foreign judgments
Original discussions surrounding the 2019 Hague Convention on Judgments and the changes contemplated by the new US Restatement on Conflict of Laws
US, EU, French and English perspectives integrated throughout the text to ensure maximum relevance and encourage students to make comparative assessments
Carefully selected extracts from primary and secondary sources that build a clear picture of the field, as well as expert analytical commentaries and questions that set these extracts in context.
Offering a unique comparison between the civil law and common law perspective, this revised and updated edition will be a key resource for students in private international law and conflict of law courses. Conflict of Laws: A Comparative Approach will also help to train lawyers who not only know the law of their own jurisdiction, but also need to have an understanding of the key differences between models, in order to be able to interact successfully with clients from other jurisdictions.
Contents
Contents: Preface Introduction to Conflict of Laws: A Comparative Approach PART I CHOICE OF LAW 1. Competing methodologies 2. The choice of law process PART II JURISDICTION 3. Variety of jurisdictional rules 4. Parallel litigation 5. Choice of court agreements PART III FOREIGN JUDGMENTS 6. Foreign nation judgments 7. Sister states' judgments PART IV CONTRACTS 8. Jurisdiction in contractual matters 9. Choice of law in contractual matters PART V TORTS 10. Choice of law in tort matters Short bibliography Index
