"An analysis of why the Hague Judgments Project failed is of significant academic and practical merit … [This book] is of a most impressive standard… with first rate original analysis."
Professor Peter McEleavy, University of Dundee
"... a very useful way for readers to understand the current US and EU approaches to jurisdiction... [A]ll those interested in jurisdiction from a private international law perspective should find [this] stimulating to read"
Professor Paul R Beaumont, University of Aberdeen
International Civil and Commercial litigation practice often faces the problem of lacking a global jurisdiction and judgments convention. This book seeks to explore the deep conflicts between the US and the EU regarding jurisdictional issues and helps identify the true hurdles in reaching a global jurisdiction and judgments convention at The Hague.
Features
A critical examination of the domestic jurisdictional systems of the two main players, the US and EU at The Hague
An analysis on the respective advantages and disadvantages of the two systems
A revelation of the confrontation and the real difficulties at The Hague.
Benefits
Useful for readers to understand the background and current US and EU approaches to jurisdiction starting from scratch
Gives deep analysis and comparison on the topic as the book progresses supported by (i) case law of various jurisdictions including the EU, US, UK and other countries and (ii) official documents of international conventions
Provides inspiring suggestions and possible ways ahead
Suitabledemics, researchers, practitioners engaging in international litigation and students.