An Introduction to the Comparative Study of Private Law Readings, Cases, Materials
James Gordley, Arthur Taylor von Mehren
This book compares the law of property, contract, tort and unjust enrichment in two common law jurisdictions: the United States and England, and two civil law jurisdictions: France and Germany. Readings explore the fundamental differences of origin, of codification, and of the legal structure and legal profession between both. The core of the book consists of cases, statutes and code provisions which provide a road map of the basic doctrines of private law in these jurisdictions and allow one to consider to what extent their approaches and their solutions differ.
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