Summary
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. -- Provided by publisher.
Contents
Competing methodologies
The choice of law process
General rules
Parallel litigation
Choice of court agreements
Foreign nation judgments
Sister states judgments
Jurisdiction in contractual matters
Choice of law in contractual matters
Choice of law in tort matters
Validity of marriage
Divorce.