The United Nations Convention on Contracts for the International Sale of Goods (CISG), adopted in April 11, 1980, is an attempt to unify rules of international trade. A large number of states that represent a variety of legal systems and of degrees of development have adhered to this Convention. / As a result of the divergence of approaches and rules in these systems, several issues were debated during the negotiations, among others the remedy of specific performance. / This thesis examines the provisions regarding specific performance in the Convention in attempt to reveal the divergence of approaches between Common Law and Civil Law by means of a comparative study of the two systems. / The purpose is to assess the extent to which uniformity is achieved in the Convention. The study shows that the solution adopted regarding specific performance was a compromise that threatens uniformity to a certain degree.

Any contract for the sale of goods between international commercial traders may be subject to the U.N. Convention on Contracts for the International Sale of Goods (CISG). If a buyer suffers damages as a result of a breach of contract, she is entitled to damages under the Convention. The issue in this thesis is whether a buyer may also invoke product liability actions under national tort law if a defective good causes bodily injury or property damage. The provisions of the CISG generally displace national law governing the rights and obligations deriving from a contract of sale. Despite the desirability of removing the uncertainties of foreign liability regimes from international trade, domestic rules of product liability remain, in general, applicable. Only if national tort actions interfere with the core of the Convention's liability regime, must the domestic law be modified.

Thesis (doctoral)--Universität Göttingen.

No description available.

No description available.

Thesis (M.A.). / Cover title. Mimeo. copy. Includes bibliographical references.

published_or_final_version / Economics / Master / Master of Arts

Thesis (M.A.). / Cover title. Mimeo. copy. Includes bibliographical references.

Thesis--University of Wisconsin--Madison. / Typescript. Vita. eContent provider-neutral record in process. Description based on print version record. Includes bibliographical references (leaves 251-258).

Thesis (Ph. D.)--University of Wisconsin-Madison, 1985. / Typescript. Vita. Includes bibliographical references (leaves 101-108).