Jacob Ziegel

Contents: Conflict of Laws Regarding Liability Allocation between Insurers in Cases of Double Insurance by Michael Bogdan The Rise and Rise of Standard Form Contracts: International Commodity Sales 1800-1970 by Ross Cranston Is the Lex Mercatoria Autonomous? by Roy Goode Letters of commitment and loan agreements by Lars Gorton Law of business in transition in Hungary by Attila Harmathy Commercial Law: is it Special? by Ewoud Hondius A Roadmap to Economic Development through Law: Third Parties and Comparative Legal Culture by Boris Kozolchyk Last Shot vs. Knock Out – Still Battle over the Battle of Forms Under the CISG by Ulrich Magnus Directive 2000/35 of 29 June 2000 on combating late payment in commercial transactions: the period for payment (art. 3.1 b) by Pilar Perales Viscasillas Electronic Communications and Incoterms 2000 by Jan Ramberg Calculation of damages in case of anticipatory breach under the CISG by Peter Schlechtriem Ethical Values and International Sales Contracts by Ingeborg Schwenzer & Benjamin Leisinger The Globalization of Law and its Limitations, with Particular Reference to the Globalization of Commercial Law by Jacob Ziegel

All modern legal systems with advanced economies must address the question of how to respond to the needs of insolvent consumers whose burden of debt greatly exceeds their capacity to repay within a reasonable time frame. This study surveys comparatively the insolvency regimes currently in place or likely to be adopted in the foreseeable future in Canada,the United States, Australia, England and Wales, Scotland, Scandinavia and a representative group of Western countries on the continent of Europe. Modern legal systems have two basic alternatives in providing relief for over-committed consumers. The first, which involves restricting the enforcement of individual creditor remedies is a method with which this study is not concerned. Where the consumer is seriously insolvent and owes money to many creditors, a different approach is required -- a collective solution to debtor's problems - and this, the solution provided by modern insolvency systems, is the focus of this study.