Stefano Dominelli (Università di Genova) has simply revealed a ebook titled Regolamento Bruxelles I bis e US jurisdiction in personam: riflessioni e proposte su condivisioni valoriali, influenze e osmosi di metodi with Editoriale Scientifica. The ebook is written in Italian but additionally options conclusions in English.
The creator has kindly shared the next abstract with us:
The ebook analyses the essential ideas of the EU’ and US worldwide civil process in contract and tort regulation. The investigation reveals how each methods are partly inconsistent with their respective premises – of authorized certainty, on the one hand, and equity and justice, on the opposite. The juxtaposition of the dogmatic approaches and their contextualisation within the gentle of the regulation in motion makes it potential to reconstruct a typical and shared precept which shapes options in each methods – that of the required existence of a minimal connection between the jurisdiction and the case. This conclusion opens up, to a restricted extent, to a conceptual rapprochement between authorized methods and to reflections on potential authorized transplants that respect the traits of the native authorized tradition.
The entire ebook is out there open entry below this hyperlink.
