Document Type

Article

Publication Title

Louisiana Law Review

Abstract

These brief observations should be sufficient to disprove the -statement that the "foreseeability limit" as laid down in CISG article 74 corresponds to a rule which finds its source in common law rules. And it is on the basis of this conclusion that one can divide all legal systems into four different categories: the countries which recognize the "foreseeability" limit as laid down in French law; the countries which are somehow based on the Hadley rule; the legal systems which ignore the limit at issue, except for international sales contracts, such as Germany; and those systems which do not recognize a similar principle at all.

First Page

1257

Volume

53

Publication Date

1993

Share

COinS