For every transnational lawyer, it is vital to know the differences between national secured transactions laws. Since the applicable law is determined by the pl

The Draft of a Common Frame of Reference (DCFR) is based in part on a revised version of the Principles of European Contract Law (PECL) and contains Principles,

One of the most important characteristics of today’s private law is that it increasingly flows from different sources: Next to national legislation and case l

Winner of the 2016–2018 KG Idman Prize. This monograph seeks the optimal way to promote compatibility between systems of proprietary security rights in Europe

This work is inspired by the comparative study published in The Interaction of Contract Law and Tort and Property Law in Europe (ISBN 3 935808 20 8-Cloth-$79.00