Document Type

Article

Publication Title

Loyola of Los Angeles International and Comparative Law Review

Abstract

Practitioners -- of comparative law focus their attention mainly on Western European, Eastern European, and common law legal systems. This focus excludes South American systems, which will be discussed in this Article. South American legal systems are nearly all considered to be civil law systems. These systems are based upon various European codes, including the French Code Civil and the German Birgerliches Gesetzbuch. Laws governing the formation of contracts are no exception. In fact, this is an area where it is particularly easy to identify codes that inspired the legal systems under review. By doing so, this Article will first examine some preliminary considerations, and then focus on the theories of "offer" and "acceptance" to determine when the contract is formed.

First Page

629

Volume

16

Publication Date

1994

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