Document Type

Article

Comments

Published in: Cornell International Law Journal, vol. 37, no. 1 (2004).

Abstract

Japanese and U.S. legal systems, despite surprisingly similar doctrine and outlook on matters of jurisdiction and judgments, often clash: jurisdictions overlap and judgments may go unrespected, while parallel proceedings persist. The current outlook for harmonization through a multilateral Hague convention of general scope is bleak. These two countries are, however, ideally situated to reach a highly feasible bilateral agreement that would provide a better tomorrow in which jurisdiction was allocated appropriately and judgments were respected accordingly.

Date of Authorship for this Version

9-8-2004

Keywords

Foreign judgments, Japan

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Jurisdiction Commons

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