The comparative analysis contained speculates on the potential similarities and differences of these sectors, intending to enunciate rules which are common in international commercial law and at the same time to select the solutions which seem best adapted to the special requirements of international trade. One should note, however, that to the extent this contribution doesn''t give absolute priority to any one of the three instruments, whenever it is necessary to choose between conflicting rules and sometime then to derive a number of general principles which apply to all of the rules, what''s decisive to the criterion used is not just which rule is mandatory or adopted by the majority of jurisdictions, but rather which of the rules under consideration have the most persuasive value and/or appear to be particularly well suited for international commercial transactions.
LIST OF ABBREVIATIONS
A. For Documents
BGB German Civil Code
Chinese CL Chinese Contract Law
CISG/Convention United Nations Convention on Contracts for the International Sale of Goods
Clunet Journal du Droit International
CLOUT Case Law on UNCITRAL Texts
COM Working Documents of the European Commission
Contract Code Contract Code Drawn upon on behalf of the English Law Commission
Draft 1978 Draft of the CISG
HGB German Commercial Code
ILR International Law Report
ITC International Trade Code
OJ Official Journal of the European Communities / Union
O.R. Official Records of the 1980 Vienna Conference
PECL/European Principles Principles of European Contract Law
Secretariat Commentary Secretariat Commentary on the 1978 Draft of the CISG
TLDB CENTRAL Transnational Law Database
UCC Uniform Commercial Code
ULF Uniform Law on the Formation of Contracts for the International Sale of Goods
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