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STUART DUTSON Produc t Liability and Private International Law: Choic e of Law in Tort in England I. INTRODUCTION The determination of whic h law should be applicable in interna tional product liability litigation is a problem tha t ha s often bedeviled th e court, jurists and practitioners alike. Whilst product liability problems can be entirel y domestic, th e natur e of th e design, manufac ture, supply, and consumption of products , and th e damag e tha t they can do if defective, is such tha t a product liability problem can involve a plethora of materia l international elements. The internationaliza tion of world trad e bears this out further — a consumer reaching for a piece of fruit or selecting a motor vehicle, or a business purchasing new equipment or obtaining intermediate goods, may well find that the product that it selected was manufactured overseas. Moreover, th e finished product may itself consist of a mix of domestic and for eign parts. The product or one or more of it s components may have been designed overseas and manufactured there or elsewhere. How ever, th e internationa l dimension in a product liability
American Journal of Comparative Law – Oxford University Press
Published: Jan 1, 1999
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