A Global Law of Jurisdiction and Judgments: Views from the United States and Japan
Kevin Clermont
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Kevin Clermont: Cornell Law School
Cornell Law School Working Papers from Cornell Law School
Abstract:
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.
Keywords: Judgments; Japan (search for similar items in EconPapers)
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