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Direct freedom of choice is, thus, well established and not seriously called into question. This, in turn, means, that the first requirement for regulatory competition in contract law is usually met.

Vischer, L. Huber and D. Both authors do not accept freedom of choice as independent connecting factor but follow the localisation theory of Henri Batiffol.

As a result, they regard a choice of law as one of many factors that help to assign a contract to a legal order. Ott and H. First, the theory assumes that businesses and consumers are fully informed about different contract laws and that choosing the applicable contract law via a choice of law-clause, thus, does not incur any costs.

Therefore, businesses and consumers must gather information about the pertaining rules and regulations in order to make an informed choice.

And even though technical progress, most importantly the internet, has reduced these costs,17 they will never be zero.

Second, the theory of regulatory competition assumes that businesses and consumers exercise their choice based on the quality of the law meaning that they choose the law that best matches their preferences.

Eger, J. Bigus, C. Ott and G. Internationalization of the Law and its Economic Analysis. See also J. Basedow and T. Fuchs, H. Schwintowski and D.

See generally on information problems as restriction of regulatory competition D. Kiwit and S.

However, drawing this conclusion means jumping to conclusions. This is because regulatory competition does not require that all businesses and consumers exercise their choice based on the quality of the law.

Rather it is sufficient that a substantial number of businesses and consumers respond to differences in legal rules on the basis of their quality.

I submit that there is conclusive empirical evidence that this requirement is met. During the last couple of years a number of empirical studies have dealt with choice of law clauses in international or, in the United States, interstate contracts.

She shows that German handbooks always recommend the choice of German law, whereas English and French handbooks always advocate the choice of English and French law respectively.

See for a detailed analysis of network effects in the context of regulatory competition A. Schwenzer ed , Schuldrecht, Rechtsvergleichung und Rechtsvereinheitlichung an der Schwelle zum See also Kieninger, n 4 above, The first study that deserves to be mentioned here was conducted by Stefan Vogenauer and Stephen Weatherill in They found out that the possibility to choose the applicable law was important to 83 percent24 and that 43 percent had at least occasionally chosen a foreign contract law in the past.

He studied choice of law clauses in contracts that were referred to arbitration before the International Court of Arbitration ICA and discovered that out of all cases filed with the ICA in , parties opted for a national contract law in The answers revealed that the possibility of choosing the applicable law was important or very important for 91 percent28 and that 85 percent had at least 23 S.

Vogenauer and S. That choice of law is an important factor when drafting international contracts also follows from a study recently conducted by David T.

He explored the approach lawyers of different countries, practice sectors and legal traditions adopt in regard to international contract formation including, among others, choice of law.

He found converging attitudes towards the design of international contracts. Most importantly, he found that out of a set of five factors choice of law, preventative measures, costbenefit-analysis, enforcement, cultural concerns , lawyers across countries considered choice of law to be the most important factor when drafting international contracts.

See D. Note, that it is not quite clear how Voigt arrives at these results given that the total number of cases filed with the ICA in was Note also that in 16,07 percent of the cases parties opted for a non-state law such as the lex mercatoria.

For obvious reasons, however, these choice of law-clauses do not need to be counted for the purpose of this article. Vogenauer and C.

See also the study by Ackerman, n 25 above. Of course, this does not mean that all businesses and consumers enter into choice of law-clauses.

And, of course, it cannot be excluded that the studies suffer from self-selection bias. For example, it cannot be excluded that they focus on contracts that are generally more likely than others to contain a choice of law-clause.

However, as mentioned earlier, it does not need very much to stir regulatory competition. All that is necessary is that a substantial number of businesses and consumers actually exercise their freedom of choice.

And the studies cited above strongly indicate that this substantial number actually exists. The empirical evidence thus suggests that the costs associated with a choice of the applicable contract law does not prevent a substantial number of parties from choosing the applicable contract law in practice.

More intricate than the question of whether a substantial number of parties exercise their freedom of choice is the question of whether a substantial number of parties actually base their choice on the quality of the law.

What are the reasons for a choice of law? What are the key factors for the choice of a particular contract law? Fortunately, several empirical studies, including some of the above 29 Vogenauer and Hodges, n 28 above, 13 question Eisenberg and G.

Due to the differences in methodology, sample and geographic focus the results of the studies naturally vary.

And so do the conclusions that the authors draw from them. However, all the studies show that the quality of the chosen law does play an important role in the selection of the applicable law.

This holds true for the study of Vogenauer and Weatherill conducted in They asked businesses what characteristics of a contract law influenced their choice.

They asked businesses which factors they took into account when choosing the governing contract law and allowed businesses to choose from a list of non-legal factors like language, procedural factors like the availability of certain dispute resolution schemes, and qualitative factors like fairness and predictability of outcomes as well as the quality of the contract law as such.

Most of the respondents pointed to qualitative factors, notably the quality of the contract law as such. However, it should be noted that they also show that the quality of the law is not the only factor that affects the decision to choose the applicable law.

See also Vogenauer and Weatherill, n 24 above, table 3. It merely needs to be a sufficiently important one for a sufficiently large number of businesses and consumers.

In fact, regulatory competition would only be excluded, if all parties based their choice exclusively on the familiarity of the chosen law.

To draw a comparison: in Germany, most people buy German cars. The same holds true for purchasers domiciled in other countries, notably France43 and Japan.

And this is clearly not the case when it comes to contract law. Take again the study of Vogenauer and Weatherill in they found out that 21 percent of the businesses asked preferred not to contract under their home law.

And both numbers indicate that the quality of the law is not, at least not only, a function of familiarity. Empirical evidence thus suggests that a substantial number of businesses and consumers actually respond to differences in legal rules and that they do so based on the quality of the law.

As a result, there are good reasons to believe that on the demand side the requirements for regulatory competition are generally met.

See Verband der Automobilindustrie, n 43 above. The only possible source of income seems to be an increase in tax revenue resulting from more local lawyers working on international contract cases.

Gatsios and P. See generally on the factors that influence state actions from an economic perspective L. See also the discussion by H.

See also F. Parisi and L. Eger and H. Streit and A. This is because states are not in a position to take note of choice of law-clauses across the board and to identify the causes for the choice of a particular contract law.

However, such surveys are difficult and, thus, costly to conduct. In addition, they do not necessarily lead to useful results since businesses and consumers might have different reasons to choose a particular law.

States may have a hard time to adjust their contract laws in a targeted fashion. Many academics, therefore, doubt that the requirements relating to the supply side of regulatory competition are actually met in practice.

Recent developments, however, show that states indeed express an interest in having their contract laws applied and that they are willing to adjust their contract laws to the needs of businesses and consumers.

It emphatically describes the alleged advantages of English law57 and specifically the advantages of English contract law.

English law allows the parties to agree the proportion of benefits which may accrue to either party, allowing the parties much greater flexibility of arrangements than under many civil codes.

Just like the other brochures it specifically focuses on contract law. In contrast to English law, a contract under German law requires no detailed provisions and definitions on issues such as right of retention, set-off or assignment, as these have already been provided by the legislator.

Unless the contract expressly stipulates otherwise, the statutory provisions will apply. It not only contains general provisions applicable to all contracts, but also specific rules for different types of contracts.

These rules provide what are deemed to be equitable solutions to problems that individuals and businesses are likely to encounter in ordinary contracts.

They also enable contracts to be written clearly and succinctly, thereby making them less costly and afford a higher degree of legal certainty.

Contrary to common law countries, the parties do not have to create their own rules for each contract; the contract only needs to stipulate clauses on issues on which the parties wish to exclude or supplement the rules of the Code.

In continental law countries the provisions of contract law are not mandatory on the contracting parties, who are, in principle, free to modify the statutory provisions, in whole or in part, in accordance with the principle of freedom of Bereitgestellt von Staats- und Universitaetsbibliothek Hamburg Angemeldet And, second, they want to attract foreign businesses.

In addition to having an interest in application of their contract laws, states must actually be willing to adjust their contract laws to the needs of businesses and consumers.

Some authors doubt that this is actually the case. First, law reform is a lot more costly than promotion.

It is, therefore, rational that states first resort to promotion in order to attract businesses before they engage in law reform. However, there should be little doubt that states will also be willing to change their contract laws if they actually have to, ie if promotion does not actually attract businesses and consumers.

Second, and more importantly, it is not true that states have not changed their contract laws during the last years. In fact, a large number of states have partly or wholly revised their contract laws over the last two decades.

Take, for example, Germany. After more than 20 years of preparatory work the federal legislator introduced a new law on contractual contract.

This allows the parties to individualize their contractual relationships or to devise new rules for them. Most importantly, you need a functioning and predictable legal infrastructure.

Germany more than meets all of these requirements. See for a detailed account S. See for a detailed account I. See for a detailed account L.

See for a detailed account V. Hartlief and C. This Code, however, did merely take over the old Yugoslav Act of Obligations and did not contain substantial changes.

See for a detailed account D. In Serbia and Spain plans to reform the law of contractual obligations are under way.

See for a recent account M. Jerez Delgado and M. Finally, the Australian government recently undertook a public consultation to explore the scope for reforming Australian contract law.

However, it was a sufficiently important one. Again, it is sufficient that a substantial number does so.

While still at university he became part of "academixer" , a student cabaret group of which in September Hart was one of four founding members.

He continued as its leader till and remained closely associated with it till his death. He continued to head up the university's "Poetic Theatre" till or Katrin Bremer joined "academixer" in , which was the year in which she and Jürgen Hart first met.

She came originally from Rostock in the north. Eight years younger than her future husband, she had come to Leipzig to study "arts and theatre studies".

His focus switched to solo programmes and, with Katrin Hart, two-person programmes. During the s Hart also made a series of appearances as a stage actor.

In he took the lead role as himself in "Augen zu und durch — die unernste Geschichte Sachsens", an alternative history of the downs and ups of Saxony, when it was staged at the Chemnitz Theatre.

He himself was the author of the work. The production was directed by another Saxon , Christoph Brück.

His detective novel "Die Oma im Kühlschrank" "Granny in the fridge" was published in Märchen ohne Grimm und Groll" which appeared in Jürgen Hart was the author of more than 40 cabaret programmes, many of which became available on gramophone records and successor media.

Many elements from his programmes were re-enacted by other cabaret companies such as, in particular, the Leipziger Pfeffermühle "Leipzig Peppermill".

In March , a few weeks before he died, received the Saxon Order of Merit. What will then be left will be "Sing, mei Sachse, sing", which has already become a latter-day folk song".

The song was published in with words by Jürgen Hart and a melody by Arndt Bause. Almost , copies of the recording were sold at the time.

It became known that Jürgen Hart was seriously ill in October he died of bone cancer half a year later. His family implemented his wish that his grave should be positioned next to that of the Saxon dialect poet Lene Voigt in Leipzig 's Südfriedhof South Cemetery.

Jürgen Hart's widow Katrin remains a member of the "academixer" cabaret. From Wikipedia, the free encyclopedia.

Retrieved 2 July

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DOI Initially, the focal point of the debate was corporate law. Only recently the attention has shifted to other areas of law, notably contract law.

In the first part of the following article I argue that this question must be answered in the affirmative: empirical evidence shows that there is regulatory competition in contract law just like in other areas of law, notably corporate law.

Most importantly, empirical evidence shows that businesses and consumers actually choose the applicable contract law based on the quality of the law and that states actually respond to these choices by adjusting their contract laws.

With this finding, however, the discussion about regulatory competition in contract law has not yet reached its end.

To the contrary: the fact that states actually do compete for application of their contract law raises a number of normative questions.

Should regulatory competition be promoted because it induces a race to the top? Should it be banned because it induces a race to the bottom?

In the second part of the paper I argue that regulatory competition in contract law will generally induce a race to the top.

It should, therefore, generally be promoted. However, I also argue that regulatory competition may induce a race to the bottom in some cases, namely where a choice of law does not account for the interests of all parties affected by the choice.

In these cases, I conclude, that regulatory competition should be regulated. More specifically, I argue that it should be regulated on the level of private international law by limiting freedom of choice.

I thank all participants for their valuable comments. All remaining errors are mine. Bereitgestellt von Staats- und Universitaetsbibliothek Hamburg Angemeldet Im Gegensatz zum Gesellschaftsrecht, wo sowohl in den USA als auch in Europa mittlerweile anerkannt ist, dass Staaten um die Anwendung ihres Rechts konkurrieren, ist im Vertragsrecht allerdings unklar, ob es einen Wettbewerb der Rechtsordnungen gibt.

Der erste Teil des nachfolgenden Beitrags legt dar, dass diese Frage im Hinblick auf das Vertragsrecht ebenso zu bejahen ist wie im Hinblick auf andere Bereitgestellt von Staats- und Universitaetsbibliothek Hamburg Angemeldet Vielmehr stellen sich zahlreiche normative Fragen.

Insbesondere sollte auf der Ebene des Internationalen Privatrechts die Rechtswahlfreiheit begrenzt werden. Only recently has attention shifted to other areas of law, notably contract law.

However, in contrast to corporate law, where there is little doubt that states do Bereitgestellt von Staats- und Universitaetsbibliothek Hamburg Angemeldet In addition, I will discuss some normative implications that follow from the empirical evidence infra C.

B Empirical Evidence The discussion about regulatory competition is based on the economic theory of jurisdictional competition.

In its original form, this theory goes back to Charles M. I The Demand Side On the demand side, regulatory competition requires that businesses and consumers are in a position to choose the applicable law.

In addition, it requires that businesses and consumers are actually responsive to differences in legal rules. See for a detailed account W.

Bratton and J. It comes along in two different forms: direct and indirect. It is indirect if parties may influence facts that determine the applicable law.

In corporate law, for example, many states follow the incorporation theory and apply the law of the state where the company was incorporated.

In contract law, freedom of choice is widely recognized in its direct form. With the exception of some Middle Eastern and Latin American countries,6 notably Bolivia, Brazil, Columbia and Uruguay,7 most national and international private international law regimes allow parties to choose the law applicable to their contract via a choice of law-clause.

In Mexico and Venezuela, freedom of choice applies according to Article 7 of the Mexico Convention on the law applic- 5 See for this distinction L.

They are expected to be adopted in the near future. Lebedev, A. Muranov, R. Khodykin and E. Article 1 of the Peruvian Civil Code, for example, provides that contracts are governed by the law chosen by the parties.

Direct freedom of choice is, thus, well established and not seriously called into question. This, in turn, means, that the first requirement for regulatory competition in contract law is usually met.

Vischer, L. Huber and D. Both authors do not accept freedom of choice as independent connecting factor but follow the localisation theory of Henri Batiffol.

As a result, they regard a choice of law as one of many factors that help to assign a contract to a legal order. Ott and H.

First, the theory assumes that businesses and consumers are fully informed about different contract laws and that choosing the applicable contract law via a choice of law-clause, thus, does not incur any costs.

Therefore, businesses and consumers must gather information about the pertaining rules and regulations in order to make an informed choice.

And even though technical progress, most importantly the internet, has reduced these costs,17 they will never be zero. Second, the theory of regulatory competition assumes that businesses and consumers exercise their choice based on the quality of the law meaning that they choose the law that best matches their preferences.

Eger, J. Bigus, C. Ott and G. Internationalization of the Law and its Economic Analysis. See also J.

Basedow and T. Fuchs, H. Schwintowski and D. See generally on information problems as restriction of regulatory competition D.

Kiwit and S. However, drawing this conclusion means jumping to conclusions. This is because regulatory competition does not require that all businesses and consumers exercise their choice based on the quality of the law.

Rather it is sufficient that a substantial number of businesses and consumers respond to differences in legal rules on the basis of their quality.

I submit that there is conclusive empirical evidence that this requirement is met. During the last couple of years a number of empirical studies have dealt with choice of law clauses in international or, in the United States, interstate contracts.

She shows that German handbooks always recommend the choice of German law, whereas English and French handbooks always advocate the choice of English and French law respectively.

See for a detailed analysis of network effects in the context of regulatory competition A. Schwenzer ed , Schuldrecht, Rechtsvergleichung und Rechtsvereinheitlichung an der Schwelle zum See also Kieninger, n 4 above, The first study that deserves to be mentioned here was conducted by Stefan Vogenauer and Stephen Weatherill in They found out that the possibility to choose the applicable law was important to 83 percent24 and that 43 percent had at least occasionally chosen a foreign contract law in the past.

He studied choice of law clauses in contracts that were referred to arbitration before the International Court of Arbitration ICA and discovered that out of all cases filed with the ICA in , parties opted for a national contract law in The answers revealed that the possibility of choosing the applicable law was important or very important for 91 percent28 and that 85 percent had at least 23 S.

Vogenauer and S. That choice of law is an important factor when drafting international contracts also follows from a study recently conducted by David T.

He explored the approach lawyers of different countries, practice sectors and legal traditions adopt in regard to international contract formation including, among others, choice of law.

He found converging attitudes towards the design of international contracts. Most importantly, he found that out of a set of five factors choice of law, preventative measures, costbenefit-analysis, enforcement, cultural concerns , lawyers across countries considered choice of law to be the most important factor when drafting international contracts.

See D. Note, that it is not quite clear how Voigt arrives at these results given that the total number of cases filed with the ICA in was Note also that in 16,07 percent of the cases parties opted for a non-state law such as the lex mercatoria.

For obvious reasons, however, these choice of law-clauses do not need to be counted for the purpose of this article.

Vogenauer and C. See also the study by Ackerman, n 25 above. Of course, this does not mean that all businesses and consumers enter into choice of law-clauses.

And, of course, it cannot be excluded that the studies suffer from self-selection bias. For example, it cannot be excluded that they focus on contracts that are generally more likely than others to contain a choice of law-clause.

However, as mentioned earlier, it does not need very much to stir regulatory competition. All that is necessary is that a substantial number of businesses and consumers actually exercise their freedom of choice.

And the studies cited above strongly indicate that this substantial number actually exists. The empirical evidence thus suggests that the costs associated with a choice of the applicable contract law does not prevent a substantial number of parties from choosing the applicable contract law in practice.

More intricate than the question of whether a substantial number of parties exercise their freedom of choice is the question of whether a substantial number of parties actually base their choice on the quality of the law.

What are the reasons for a choice of law? What are the key factors for the choice of a particular contract law? Fortunately, several empirical studies, including some of the above 29 Vogenauer and Hodges, n 28 above, 13 question Eisenberg and G.

Due to the differences in methodology, sample and geographic focus the results of the studies naturally vary.

And so do the conclusions that the authors draw from them. However, all the studies show that the quality of the chosen law does play an important role in the selection of the applicable law.

This holds true for the study of Vogenauer and Weatherill conducted in They asked businesses what characteristics of a contract law influenced their choice.

They asked businesses which factors they took into account when choosing the governing contract law and allowed businesses to choose from a list of non-legal factors like language, procedural factors like the availability of certain dispute resolution schemes, and qualitative factors like fairness and predictability of outcomes as well as the quality of the contract law as such.

Most of the respondents pointed to qualitative factors, notably the quality of the contract law as such. However, it should be noted that they also show that the quality of the law is not the only factor that affects the decision to choose the applicable law.

See also Vogenauer and Weatherill, n 24 above, table 3. It merely needs to be a sufficiently important one for a sufficiently large number of businesses and consumers.

In fact, regulatory competition would only be excluded, if all parties based their choice exclusively on the familiarity of the chosen law.

To draw a comparison: in Germany, most people buy German cars. The same holds true for purchasers domiciled in other countries, notably France43 and Japan.

And this is clearly not the case when it comes to contract law. Take again the study of Vogenauer and Weatherill in they found out that 21 percent of the businesses asked preferred not to contract under their home law.

And both numbers indicate that the quality of the law is not, at least not only, a function of familiarity.

Empirical evidence thus suggests that a substantial number of businesses and consumers actually respond to differences in legal rules and that they do so based on the quality of the law.

As a result, there are good reasons to believe that on the demand side the requirements for regulatory competition are generally met.

See Verband der Automobilindustrie, n 43 above. The only possible source of income seems to be an increase in tax revenue resulting from more local lawyers working on international contract cases.

Gatsios and P. See generally on the factors that influence state actions from an economic perspective L. See also the discussion by H.

See also F. Parisi and L. Eger and H. Streit and A. This is because states are not in a position to take note of choice of law-clauses across the board and to identify the causes for the choice of a particular contract law.

She came originally from Rostock in the north. Eight years younger than her future husband, she had come to Leipzig to study "arts and theatre studies".

His focus switched to solo programmes and, with Katrin Hart, two-person programmes. During the s Hart also made a series of appearances as a stage actor.

In he took the lead role as himself in "Augen zu und durch — die unernste Geschichte Sachsens", an alternative history of the downs and ups of Saxony, when it was staged at the Chemnitz Theatre.

He himself was the author of the work. The production was directed by another Saxon , Christoph Brück. His detective novel "Die Oma im Kühlschrank" "Granny in the fridge" was published in Märchen ohne Grimm und Groll" which appeared in Jürgen Hart was the author of more than 40 cabaret programmes, many of which became available on gramophone records and successor media.

Many elements from his programmes were re-enacted by other cabaret companies such as, in particular, the Leipziger Pfeffermühle "Leipzig Peppermill".

In March , a few weeks before he died, received the Saxon Order of Merit. What will then be left will be "Sing, mei Sachse, sing", which has already become a latter-day folk song".

The song was published in with words by Jürgen Hart and a melody by Arndt Bause. Almost , copies of the recording were sold at the time.

It became known that Jürgen Hart was seriously ill in October he died of bone cancer half a year later. His family implemented his wish that his grave should be positioned next to that of the Saxon dialect poet Lene Voigt in Leipzig 's Südfriedhof South Cemetery.

Jürgen Hart's widow Katrin remains a member of the "academixer" cabaret. From Wikipedia, the free encyclopedia.

Retrieved 2 July Der Spiegel online. Der Leipziger Kabarettist wäre in diesem Jahr 70 geworden. Die Biographie".

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JГјrgen Hart Video

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