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Loose Ends and Contorts in International Sales: Problems in the Harmonization of Private Law Rules

Loose Ends and Contorts in International Sales: Problems in the Harmonization of Private Law Rules JOSEPH M. LOOKOFSKY* Loos e Ends and Contorts in International Sales: Problem s in the Harmonization of Privat e Law Rules INTRODUCTION In a well-integrated world, the formal harmonization of private law would keep pace with the globalization of private business. In the real world, international legislation may limp awkwardly behind the national pace. Not only is it often difficult to compro­ mise and agree on content; it may not even be possible to lop off a clear-cut chunk of law as grist for the harmonization mill. The leg­ islator cannot always delimit and divide his subject matter into neat and tidy compartments of issues and rules . . . "little sovereign states". So, many international problems are still resigned—by default— to conflicts of law and other national rules. And the resulting col­ lage of national and international rules may make for a less than co­ hesive system. The latest—and arguably the greatest—legislative achievement aimed at harmonizing private commercial law is the "CISG": the United Nations (Vienna) Convention on Contracts for the Interna­ tional Sale of Goods. The CISG is the product of a 50-year transna­ tional effort, and it surely represents a giant step forward in the JOSEPH http://www.deepdyve.com/assets/images/DeepDyve-Logo-lg.png American Journal of Comparative Law Oxford University Press

Loose Ends and Contorts in International Sales: Problems in the Harmonization of Private Law Rules

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Publisher
Oxford University Press
Copyright
© 1991 by The American Association for the Comparative Study of Law, Inc.
ISSN
0002-919X
eISSN
2326-9197
DOI
10.2307/840785
Publisher site
See Article on Publisher Site

Abstract

JOSEPH M. LOOKOFSKY* Loos e Ends and Contorts in International Sales: Problem s in the Harmonization of Privat e Law Rules INTRODUCTION In a well-integrated world, the formal harmonization of private law would keep pace with the globalization of private business. In the real world, international legislation may limp awkwardly behind the national pace. Not only is it often difficult to compro­ mise and agree on content; it may not even be possible to lop off a clear-cut chunk of law as grist for the harmonization mill. The leg­ islator cannot always delimit and divide his subject matter into neat and tidy compartments of issues and rules . . . "little sovereign states". So, many international problems are still resigned—by default— to conflicts of law and other national rules. And the resulting col­ lage of national and international rules may make for a less than co­ hesive system. The latest—and arguably the greatest—legislative achievement aimed at harmonizing private commercial law is the "CISG": the United Nations (Vienna) Convention on Contracts for the Interna­ tional Sale of Goods. The CISG is the product of a 50-year transna­ tional effort, and it surely represents a giant step forward in the JOSEPH

Journal

American Journal of Comparative LawOxford University Press

Published: Apr 1, 1991

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