A Global Law of Jurisdiction and Judgments: Views from the United States and Japan
Kevin M. Clermont
Cornell Law School
Cornell International Law Journal, Vol. 37, p. 1, 2004
Cornell Legal Studies Research Paper No. 04-027
Japanese and U.S. legal systems, despite surprisingly similar doctrine and outlook on matters of jurisdiction and judgments, often clash: jurisdictions overlap and judgments may go unrespected, while parallel proceedings persist. The current outlook for harmonization through a multilateral Hague convention of general scope is bleak. These two countries are, however, ideally situated to reach a highly feasible bilateral agreement that would provide a better tomorrow in which jurisdiction was allocated appropriately and judgments were respected accordingly.
Number of Pages in PDF File: 26Accepted Paper Series
Date posted: September 8, 2004
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