Pratical Global Civil Justice: Decision According to Law in the United States, Germany and Korea: Chapter 4 The Court: Jurisdiction and Applicable Law
27 Pages Posted: 16 Nov 2009 Last revised: 14 Dec 2010
Date Written: February 5, 2010
This paper is superseded by a later draft of the complete book, which is available at http://ssrn.com/abstract=1711003.
This is a working draft of a chapter in a book for laymen that introduces and compares civil justice systems in the United States, Germany and Korea. This chapter shows how the American system pointlessly makes issues of jurisdiction complicated and expensive. It shows how the German and Korean systems resolve these same issues without expenditure of significant resources. The chapter also provides brief descriptions of the civil courts systems in the United States, Korea and Germany. It includes a Special Comment on why forum shopping is a feature of American litigation, but not of German or Korean cases.
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