Limitation of Liability - A Comparative Study - Couverture souple

Johansen, Claus Emil Engel

 
9783659384448: Limitation of Liability - A Comparative Study

Synopsis

This book deals with incorporation, interpretation and validity of liability disclaimers (LD) in unilaterally drafted B2B-standard terms in DK (civil law), England (common law) and United States of America (mostly common law). I mainly analyze the remedy of damages. Other clauses may in reality function as LDs, why the same judicial methods, as a main rule, apply in regards to these clauses also. All three countries have similar approaches, however there are differences a lawyer should be aware about when drafting contracts in these countries and also on how a lawyer should deal with these clauses in matters of dispute.

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Présentation de l'éditeur

This book deals with incorporation, interpretation and validity of liability disclaimers (LD) in unilaterally drafted B2B-standard terms in DK (civil law), England (common law) and United States of America (mostly common law). I mainly analyze the remedy of damages. Other clauses may in reality function as LDs, why the same judicial methods, as a main rule, apply in regards to these clauses also. All three countries have similar approaches, however there are differences a lawyer should be aware about when drafting contracts in these countries and also on how a lawyer should deal with these clauses in matters of dispute.

Biographie de l'auteur

I work as an attorney-at-law specializing in contract law and general business law. Additionally, I work as a lecturer at Aalborg University where I teach contract law and tort law. I have a bachelor's and a master's law degree from Aarhus University.

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