‘The New Private Law – the View from Germany’

“This summer I spent a month visiting the Max Planck Institute for Foreign and International Private Law, in the group headed by Prof Reinhard Zimmermann. It was an enjoyable and productive visit, and it prompts me to raise a comparative issue on this blog. In addition to the similarities and differences between common and civil law, which are sometimes overstated, there is a big difference between American and German private law scholarship, which is reflected in the law itself …” (more)

[Henry Smith, New Private Law, 7 September]

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