comparative study of competent law in e-contracts concluded on the internet space in perspective of usa, eu and iran legal systems

the character of cosmopolitanism in e-commerce disputes is much more complicated than in normal international transactions. internet environment has created challenges and changes about the governing law of contracts in this space. this cyber space has technical and legal differences in compared with physical environment. in this paper, we intend to answer this question that in dispute arising from an electronic commercial contract, what law governs and efficacy of parties will in determination of this law what to extent is? despite the importance of this issue, discussion of the law governing electronic contracts concluded on the internet and cyberspace in our legal literature has been little attention. in this research, with considering the latest international and domestic documents, we survey the competent law in e-contracts concluded on the internet space with a comparative and analytical approach in usa, eu and iran legal systems.