# kaal:claim:617681-016

**Claim.** The weak link in a bundled package offered by a civil law Member State is likely to be its system of adjudication rather than its statute.

**Type.** failure  **Support.** argued

**Holds when.**

- civil law Member States marketing corporate law to investors used to common law systems

**Source quote.**

> The weak link in the bundled package offered by a civil law jurisdiction is thus likely to be its system of adjudication rather its statute.

**From.** Christian Kirchner, Richard W. Painter, Wulf A. Kaal, *Regulatory Competition in EU Corporate Law after Inspire Art Unbundling Delaware's Product for Euro* (2004), D.I.2 Differences Between Common Law and Civil Law Approaches, page 25

**Cite as.** Christian Kirchner, Richard W. Painter, Wulf A. Kaal, Regulatory Competition in EU Corporate Law after Inspire Art Unbundling Delaware's Product for Euro (2004). SSRN: https://ssrn.com/abstract=617681

**Verify.** sha256 of source PDF `e142130507ea2f5b025fd97b3f762d44ee3a7aaa82b155aab63434b85e8fd834` at https://raw.githubusercontent.com/wulfkaal/Academic-Papers/main/papers/pdf/Kirchner%20et%20al.%20-%202004%20-%20Regulatory%20Competition%20in%20EU%20Corporate%20Law%20after%20Inspire%20Art%20Unbundling%20Delaware%27s%20Product%20for%20Euro.pdf

**Failure mode.** civil-law-adjudication-discount  (family: enforcement-gap)

**Topics.** institutional-design

**Keywords.** civil-law, common-law, adjudication, bundled-product

**Canonical form.** This markdown file is the canonical hashed representation of the claim. Its sha256 is the content hash used for attestation.