HOW WELL DO U.S. JUDGMENTS FARE IN EUROPE?

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					HOW WELL DO U.S. JUDGMENTS FARE IN EUROPE?
Samuel P Baumgartne
				
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Description: Class actions against foreign defendants are widespread, the Alien Tort Claims Act has emerged as a mainstay of proceedings to enforce international human rights law in US courts, and the globalization of the economy has led to an increase in transnational regulatory litigation. In this article, the author intends to provide some answers to the question of how well US judgments really fare in Europe, where many of the important trading partners of the US are located. On average, US judgments face more obstacles in Europe than do European judgments in the US. Nonetheless, much depends on the country, the subject matter involved, the person of the defendant, and the connection of the dispute to the recognition state, among other things. Thus, a multilateral judgments convention, such as the one initiated by the US in 1992, could indeed bring similar improvements like those resulting from various conventions and EC regulations adopted by the Europeans regarding their own judgments.
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