Includes bibliographical references and index.

Introduction -- Jurisdiction : an analysis -- Jurisdiction under EU law -- EU law : special jurisdiction -- EU law : the problem of pure financial loss -- The traditional English rules -- Developments in Canada -- US law : an outline -- Choice-of-court agreements -- Jurisdictional conflicts : the common-law approach -- Jurisdictional conflicts : the EU approach -- Special topic I : product liability -- Special topic II : defamation -- Introduction to Part III -- EU law -- English law : jurisdiction -- English law : defences -- US law : some highlights -- Freezing assets -- Obtaining evidence abroad : forum procedures -- Obtaining evidence abroad : international co-operation -- Introduction to choice of law -- Torts -- Contracts : the principle of party autonomy -- Contracts : legal policy and choice of law -- The common-law countries : regulating business, protecting employees and helping consumers -- Foreign currency -- Property : tangible movables -- Contractual rights and property interests - I -- Contractual rights and property interests - II -- Contractual rights and property interests - III.

"When a foreign judgment is recognized, what exactly is it that is recognized? Here there seems to be a difference between the common law and the civil law. In the civil law, it is sometimes said that the final ruling or order (in German, the Tenor or Spruch; in French, the dispositif) is all that is recognized. In the common-law world, however, the doctrine known variously as issue estoppel,2 collateral estoppel or issue preclusion3 requires a court in certain circumstances to recognize rulings by the court of origin on preliminary issues.4 Estoppel is a doctrine peculiar to the common law. It is too complex to sum up in a few words, but the underlying idea may be explained by saying that a person should not be allowed to say one thing at one time and another thing at another 2 British and Commonwealth terminology. 3 These latter two expressions are both United States terminology. 4 This raises the question which law should decide whether issue estoppel applies: should it be the law of the State of origin or that of the State of recognition"-- Provided by publisher.