kaal:claim:617681-018

Because the English common law system is gravitating toward a civil law approach that weights statutes more heavily than judicial interpretation, the value of a bundled package of statutes plus adjudication even in a European common law jurisdiction may not greatly exceed the value of the statutes standing alone.

The value of the "bundled package" of statutory law and adjudication provided by the state of incorporation even in a common law jurisdiction thus may not greatly exceed the value of the statutory law standing alone.

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, p. 26
https://ssrn.com/abstract=617681 · source PDF

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

• European common law jurisdictions, in contrast with Delaware

mechanismsupport: arguedinstitutional-design

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