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.
Key features of the second edition include:
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New topics covered in the fields of jurisdiction and foreign judgments
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Original discussions surrounding the 2019 Hague Convention on
Judgments and the changes contemplated by the new US Restatement on
Conflict of Laws
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US, EU, French and English perspectives integrated throughout the text
to ensure maximum relevance and encourage students to make comparative
assessments
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Carefully selected extracts from primary and secondary sources that
build a clear picture of the field, as well as expert analytical
commentaries and questions that set these extracts in context.
Offering a unique comparison between the civil law and common law
perspective, this revised and updated edition will be a key resource for
students in private international law and conflict of law courses.
Conflict of Laws: A Comparative Approach will also help to train lawyers
who not only know the law of their own jurisdiction, but also need to
have an understanding of the key differences between models, in order to
be able to interact successfully with clients from other jurisdictions.