federalism and conflict of laws solution system: a comparative study on conflict of laws solution system of united states of america and the european :union:

on the basis of constitution and social and cultural contexts, each country has its own private international law system. concerning countries with federal system like the united states of america, conflict of laws not only may occur between laws of the united states and law of the other countries, but also in a distinctive manner, among states of the usa together. european :union: is in the same situation. although the convention of states in europe does not frame a federal system, it has some federal characteristics, in some respects. considering the premise that the creation idea of the european :union: has been inspired by federalism principles, the purpose of this contribution is, with a descriptive and analytic- comparative manner, to explore the interstate and member states traits of conflict of laws solution systems in usa and eu in order to answer the question that “what are the differences and resemblances of eu member states conflict of laws solution system and the systems of federal countries”. finally, this paper concludes that the european :union: has unique characteristics which differentiate its conflict of laws solution system from federal systems.