Common European Sales Law and Private International Law: Some Critical Remarks

THE LAW GOVERNING SALES OF GooDs AT COMMON LAW AND UNDER THE UNIFORM SALES ACT

evasion of law in private international law

it is generally accepted that no one is allowed to abuse his legal rights accorded by a country for evasion from some limitations provided by the same country and several laws and verdicts have considered and confirmed this requirement as a rule. nevertheless there is neither common sense about neither the conditions under which such a rule may be applied nor the reactions to be taken against s...

A Logical Model of Private International Law

We provide a logical analysis of private international law, the body of law establishing when courts of a country should decide a case (jurisdiction) and what legal system they should apply to this purpose (choice of law). A formal model of the resulting interaction among multiple legal systems is proposed based on modular argumentation. It is argued that the model provided might be useful for ...

Sales Law and Inflation

Costs and Benefits of an Optional European Sales Law (CESL)

This contribution assesses the proposed Common European Sales Law (CESL) and its potential to enter into a fruitful competition with national laws (“Optional Scheme”) against the background of a more general theory on vertical regulatory competition – drawing on the much richer theory of horizontal regulatory competition (namely concerned with Delaware). It does so along three lines of argument...