Conflict of Laws: A Comparative Approach

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: • New topics covered in the fields of jurisdiction and foreign judgments • Original discussions surrounding the 2019 Hague Convention on Judgments and the changes contemplated by the new US Restatement on Conflict of Laws • US, EU, French and English perspectives integrated throughout the text to ensure maximum relevance