Francesco Castronovo
The american contract and the vienna convention: does it work?
The american contract and the vienna convention: does it work?
Summary: 1. Introduction: the conundrum of international trade. – 2. Common law and the CISG, poles apart? – 3. Article 11 and the parol evidence rule: not just a matter of evidence. – 4. Article 8 and the plain meaning rule: once again, not just a matter of evidence. – 5. The different approach to contract in common law and under the CIGS; the U.S. drafting style and the merger clause. – 6. The merger clause and the CISG. – 7. Conclusion.
