As the process of internationalization accelerates, comparative law scholars focus on the adaptation of legal cultures to new realities. It is particularly important to understand (as best we can) the "inner workings" of two groups of lawyers: those in the United States; and those in the major European countries. In which ways do the two groups understand each other, and where do they go their separate ways? And what are the implications for the legal profession and its beneficiaries of their cultural and ideological differences? At a symposium held in Paris, 12 scholars from Europe and the United States met to investigate these issues under two related rubrics: realities and trends on the one hand, and ethics, rules and professional ideologies on the other. The participants have updated their original papers for this publication. In the course of their discussion they reveal which cultural realities persist and are likely to remain, and which trends are broadening the common ground on which lawyers act in both cultures.

The papers in this volume address the provisions of the 1999 Hague Jurisdiction and Judgments Draft Convention and the state of the negotiations as of the summer of 2000. They were presented at the symposium "A Global Law of Jurisdiction and Judgments: Lessons from The Hague," held in July 2000 at the Centre Pantheon (University of Paris I Law Faculty) as a part of the Cornell-Paris I Summer Institute of International and Comparative Law. Part I focuses on the jurisdiction provisions of the 1999 Draft Convention. For the most part, the papers in Part II look to the future, though they also deal briefly with the judgments provisions of the 1999 Draft. One paper takes up changes in European Union law that will significantly affect future negotiations concerning the Draft Convention. The other two offer analyses of the major hurdles blocking the way to a successful convention and proposals for vaulting those hurdles. At the beginning of each of the two Parts a brief commentary on the papers presented in each Part is also included. The papers analyze the jurisdiction provisions of the 1999 Hague Jurisdiction and Judgments Draft Convention and shed light on many of the basic difficulties that must be resolved if a global law of jurisdiction is to be achieved. In a second part of this book, another set of papers discuss the less controversial judgments provisions of the Draft Convention, as they also look to the future of these critical international negotiations. As work on The Hague Jurisdiction and Judgments Convention continues, these papers will serve as a major reference point. The papers will also form a part of the historical background and commentary on what may become before long aglobal law of jurisdiction and judgments. Revised for this volume, the papers remain up-to-date, yielding a volume that is fundamentally forward-looking with commentary on and overview of the papers presented in each part. The benefits of this publication include critical analyses of The Hague Jurisdiction and Judgments Draft Convention by authors and editors with great expertise and reputation. This volume provides critical analyses of the Draft Convention and should appeal to any private international specialist.