Limitation of Liability - A Comparative Study.

      Аннотация: This book deals with incorporation, interpretation and validity of liability disclaimers (LD) in unilaterally drafted B2B-standard terms in DK (civil law), England (common law) and United States of America (mostly common law). I mainly analyze the remedy of damages. Other clauses may in reality function as LDs, why the same judicial methods, as a main rule, apply in regards to these clauses also. All three countries have similar approaches, however there are differences a lawyer should be aware about when drafting contracts in these countries and also on how a lawyer should deal with these clauses in matters of dispute.

Ключевые слова: Comparative study, England, Contracts, agreement, Denmark, United States of America, Common law, Liability, contract law, Civil Law, Law of Torts, Liability Disclaimer, Standard Contracts