The Transfer of Chattels in Private International Law. A comparative study. By G. A. Zaphiriou, ll.m. [University of London, The Athlone Press. 1956. xx plus 227 pp. 30s. net.]

1957 ◽  
Vol 15 (1) ◽  
pp. 109-111
Author(s):  
K. Lipstein
Keyword(s):  
Comparative Study ◽  
International Law ◽  
Private International Law

Developing Internet Jurisdiction in B2B and B2C Contracts: Focusing on Iranian Legal System with Comparative Study of American, English and eu Laws

2017 ◽  
Vol 31 (3) ◽  
pp. 276-304
Author(s):  
Taher Habibzadeh
Keyword(s):  
Comparative Study ◽  
International Law ◽  
Consumer Protection ◽  
Legal System ◽  
American English ◽  
Computer Software ◽  
Modern World ◽  
Private International Law ◽  
Habitual Residence ◽  
Electronic Communications

Abstract In the modern world, electronic communications play a significant role in areas of national and international law such as Internet jurisdiction. Private international law provides that the competent court is the court within which jurisdiction the contract is performed, so it is important to know the place of performance of the contract in the case of contracts for digital goods such as e-books or computer software delivered online. It is equally important in the case of electronic services such as e-teaching. Furthermore, as consumer protection in B2C contracts is important in developing global e-commerce, it is important to consider whether the consumer party is able to bring an action against the business party in his own place of domicile or habitual residence. The article analyses these questions and proposes ways in which the Iranian legal system might be developed to address issues of Internet jurisdiction in B2B and B2C contracts.

scholarly journals BASIC PRINCIPLES OF JURISDICTION IN PRIVATE INTERNATIONAL LAW: THE EUROPEAN UNION, THE UNITED STATES AND ENGLAND

2021 ◽  
pp. 1-16
Author(s):  
Trevor C Hartley
Keyword(s):  
United States ◽  
European Union ◽  
Comparative Study ◽  
International Law ◽  
The United States ◽  
Private International Law ◽  
The European Union ◽  
Basic Principles ◽  
Products Liability ◽  
The Law

Abstract This article consists of a comparative study of the basic principles underlying the rules of jurisdiction in private international law in commercial cases in the law of the European Union, the United States and England. It considers the objectives which these rules seek to achieve (protection of the rights of the parties and respect for the interests of foreign States) and the extent to which these objectives are attained. It takes tort claims, especially in the field of products-liability, as an example and considers which system has the most exorbitant rules. It suggests explanations for the differences found.

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