Published in: Cornell International Law Journal, vol. 37, no. 1 (2004).
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
Foreign judgments, Japan
Clermont, Kevin M., "A Global Law of Jurisdiction and Judgments: Views from the United States and Japan" (2004). Cornell Law Faculty Publications. 10.