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Introduction | |
How Contracts Are Written In Practice: | |
Negotiating international contracts: does the process invite a review of standard contracts from the point of view of national legal requirements? | |
Multinational companies and national contracts | |
Methodological Challenges: | |
Does the use of common law contract models give rise to a tacit choice of law or to a harmonised, transnational interpretation? | |
Common law based contracts under German law | |
Comparing exculpatory clauses under Anglo-American law: testing total legal convergence | |
Circulation of common law contract models in Europe: the impact of European Union system Jean-Sylvestre Bergé | |
The Applicable Law's Effects on Boilerplate Clauses: | |
The common law tradition: application of boilerplate clauses under English law | |
The Germanic tradition: application of boilerplate clauses under German law | |
The Romanistic tradition: application of boilerplate clauses under French law Xavier Lagarde | |
The Romanistic tradition: application of boilerplate clauses under Italian law | |
The Nordic tradition: application of boilerplate clauses under Danish law | |
The Nordic tradition: application of boilerplate clauses under Finnish Law | |
The Nordic tradition: application of boilerplate clauses under Norwegian law | |
The Nordic tradition: application of boilerplate clauses under Swedish law | |
The East European tradition: application of boilerplate clauses under Hungarian law | |
The East European tradition: application of boilerplate clauses under Russian law | |
Conclusion: the self-sufficient contract, uniformly interpreted on the basis of its own terms: an illusion, but not fully useless Giuditta Cordero Moss | |
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