The new rule on the assignment of rights in Rome I - the solution to all our proprietary problems? - Determination of the conflict of laws rule in respect of the proprietary aspects of assignment
Article Abstract:
The extent to which proprietary problems will be solved with the new rule on the assignment of rights in Rome I is discussed. An attempt is made to find the best solution for a conflict of laws rule in respect of the proprietary aspects of an assignment of a right, in light of the harmonization of conflict of laws within the European Union.
Publication Name: European Review of Private Law
Subject: Regional focus/area studies
ISSN: 0928-9801
Year: 2006
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Hardship in German codified private law - in comparative perspective to English, French and international contract law
Article Abstract:
A report that analyzes the German, French and English law about how a contract can be amended or terminated due to unforeseen events and describes solutions in the UN convention on Contracts for the International Sale of Goods and other similar laws is presented.
Publication Name: European Review of Private Law
Subject: Regional focus/area studies
ISSN: 0928-9801
Year: 2007
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Abuse of a relationship: undue influence in English law and French law
Article Abstract:
A report on the comparison of the protection provided by English law and French law against the abuse of relationships, where the English law applies to contracts, gifts, testamentary gifts and the French law is based on presumptions of suggestions is presented.
Publication Name: European Review of Private Law
Subject: Regional focus/area studies
ISSN: 0928-9801
Year: 2007
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