Comparative International Sales Law - Essay Example

Comparative International Sales Law Table of Contents Introduction 3 Discussion of the ment 4 Vienna Convention 7 Critical Analysis of the ment: Exploring Literatures and Past Litigations 9 Conclusion 15 References 17 Introduction Business sectors of varied nations are amongst the prime contributors towards maintaining economic growth and ensuring long-term sustainability. A huge part of the development of any nation majorly relies upon the efficiency and the scale of operations performed towards completing any particular task. Similarly, cross-border trade also has significant contribution upon the economic development of a nation. However, whether it is cross border or domestic trade, the need for enforcing strict and effective governing laws is quite crucial in each of the domains. This might be owing to the reason that in the present day business context, companies need to perform ethically and legally so that these can serve customers worldwide in an efficient manner without arising any unnecessary issue. In this regard, laws and regulations of local along with international bodies enable or influence the business units to perform their respective operations and treat the customers with utmost fairness at large1. Correspondingly, the regulations relevant to Sale of Goods that were formulated within the Vienna Convention can be prioritised to understand the universality of international sale of goods. In this present day business environment, irrespective of the status being hold by companies or any other individual, the prevalence of legal policies is quite an evident aspect to say the least. It must be mentioned that there involves numerous legal aspects, which the companies or any other individual require to comply with while performing such activities as a operational domain of business in order to maintain varied ethical norms as well as practices. It is projected that this will further ensure maximum sustainability and competitiveness for the companies operating in the global business environment2. Correspondingly, this particular theoretical concept of international sale of goods law can be seen as much prevalent in domestic as well as international operations of business. Both the sellers and the buyers possess certain legal obligations to meet or to attain the desired objectives within the approaches of conducting business in the form of selling products and/or services efficiently. In this regard, the concept of sale of goods within the international and the domestic market might be considered for further discussion. Specially mentioning, international sale of goods is primarily governed by varied laws such as CSIG and the regulations mentioned within the Benjamins Sale of Goods. The domestic sale of goods and services is principally governed by both the local and international laws in a collective manner altogether. In accordance with such laws concerning the conduct of sale of goods and services, the importance of contractual terms is considered to be paramount by a certain degree. The approaches of the individuals in performing such activities are governed by predetermined terms and conditions that hinder the involved parties to act legally and ethically3. This particular aspect not only enhances the ethicality of a particular business, but at the same time, also ensures long-term sustainability. Correspondingly, in this particular research study, focus would be levied on analysing a particular statement with the help of reviewing varied secondary sources such as journals and literatures that further justify or contradict the facts presented in the provided statement in a comprehensive manner altogether. In the process of completing the research in an effective manner, utmost attention was also paid on understanding the international laws of sale of goods and/or services with the norms elaborated in Benjamins Sale of Goods. Discussion of the Statement It has been earlier mentioned that commercial sale of goods is subjected to various legislative policies in recent times owing to the aspect that it has direct resemblance with the financial development of any particular nation. Increasing level of trade and business in a fair and efficient manner certainly results in better development of any economy. In this context, a better comprehension can be gained from the analysis of the provided statement, which has been discussed critically in the subsequent sections. Within the statement, the Benjamins Sale of Goods is deemed to be extensively prevalent, which supported in critically evaluating the provided statement in an efficient manner4. Conceptually, the idea of sale of goods involves transferring of the procession of goods from one individual to other in exchange of money or any other related factor. The Benjamins Sale of Goods is a particular literature, which covers various legal concepts and idioms associated with contract and sale of goods and services amid two parties. Apart from this, the literature also deals with depicting the terms and conditions that need to be determined while entering into a contract of sale. This particular research compilation of Michael G Bridge i.e. Benjamins Sale of Goods is often graded as a cornerstone in the domain of international sale of goods and legal implications of the same. In relation to the provided statement, the Benjamins Sale of Goods primarily deals with understanding the basic concepts of sale of goods based laws and principles. It depicts the aspects that are prevalent while conducting international trade or conducting overseas sales of goods and services at large5. The study of Bridge within the literature titled ‘Benjamins Sale of Goods’ also deals with the core principles of overseas sale of goods specifically with regards to the formation of proper and systematic contract in executing such form of trade. It is strongly believed that the studies of Bridge have resemblance with the Vienna convention wherein rules and regulations relevant to international sales of goods are widely prevalent. However, as per the statement, it is often criticised that a few of the most vital concepts of sale of goods in cross border trade and domestic markets such as c.i.f (cost, insurance, freight) and f.o.b (free on board) have relevancy within the discussion of the Vienna convention. The statement provided clearly highlights that the Vienna convention along with the insights presented by Bridge, the concepts and the implications relevant to international sale of goods are interrelated with one another. As per the contents portrayed in the literature of Benjamin’s Sale of Goods, several key factors relevant to international sale of goods law can be determined6. Correspondingly, it can be comprehended that contracts associated with the Sale of Goods are deemed to be quite important, as these directly influence the adherence to the norms of international purchase as well as sale of goods. With regards to the study of Bridge (2012) concerning Benjamin’s sale of goods, the sale of goods law within international trade is largely governed by the Sales of Goods Act 1979. It also has resemblance with the Consumer Sales Law (2009). These aspects of contracts within the Sale of Goods can be determined from the case example of BBS Group Plc v Makers (UK) Ltd and Kwei Tek Chao And Others (Trading As Zung Fu Co). V. British Traders and Shippers Ld. And N. V. Handelsmaatschappij J. Smits Import-Export, Third Party [1954] 1935 C. No. 1245 789. Observably, the rules of equity as per the law of contract law are also applicable in such Sale of Goods contract, which one way or the other influence international trade in terms of act and equity of the companies comprehensively10. In relation to the above context, it is notified that the regulations presented within the Benjamin’s sale of goods emphasised discussing c.i.f laws that were less prevalent within the approaches of the officials during the Vienna convention based on the topic of sale of goods and services in international and domestic markets. Specially mentioning, contracts that have the inclusion of c.i.f, provides the buyers with the liability to charge the sellers for any sort of damage being made in the traded products and/or services. This aspect had certainly less prevalence with the norms presented by the Vienna convention. In precise, it can be stated that the notion of c.i.f ensures rights for the buyers against the sellers in case of any damage of the product during domestic or international sale of goods. In this context, it can be justified that as per the provided statement, the norms of the Vienna convention regarding the sale of goods in the international and domestic market place less heed on addressing a few of the most common terms in the international sale of goods11. This was further amended with the help of the study or the interpretation of Bridge in Benjamin’s sale of goods. It is strongly believed that a few of the aspects such as time of shipment, which is also known as a part of Free on board (f.o.b) concept, is an integral part for the business units or individuals that are involved in international or domestic buying and selling of goods and services. It is usually the duty of the buyers to select his/her terms of shipment along with deciding the shipment period within the contract of sale of goods. In this regard, a few of the important and the most common forms of shipment terms within the f.o.b contract especially from the end of the sellers include prompt delivery of the f.o.b, mentioning the time of shipment, due conformity of the goods and services and the issues relevant to the insurance of goods among others. All these aspects are deemed to be quite important, as these impose significant impact upon the overall success of the overseas trade in an efficient manner altogether. This sort of scenario is also apparent within the past litigation of Thai Marparn Trading Co Ltd v Louis Dreyfus Commodities Asia Pte Ltd [201]12. The above discussed aspects one way or the other confirm that the text of Benjamin’s sale of goods ensures proper addressing of certain vital points to be considered during the conduct of overseas or domestic sale of goods and/or services. Correspondingly, it can be affirmed from the provided statement that the text of Benjamin’s sale of goods is indeed important in dealing with the limitations of norms of sale of goods yielded from the Vienna Convention along with the others that are being practiced in the UK13. This aspect further explains as well as determines the justifiability of the provided statement. Vienna Convention The Vienna convention is often regarded as one of the most prominent platform, wherein precise laws relevant to international sale of goods have been formulated. The conventions and the laws and principles percolate by the same, have wider applicability on the contract laws that are applicable in sale of goods in various parts of the world beyond national boundaries. There are both negative and positive aspects associated with the Vienna conventions and the decisions formulated within the same that must be taken into concern in this particular discussion. The convention and its outcome emerge with various results that one way or the other ensures greater transformation within the laws and regulations of sale of goods in the international market for any individual or nation. A few of the regulations formulated within the convention clearly highlighted the fact that states, which are under the influence of any foreign or international trade or business agreement, will be liable to meet the criteria of international law of sale of goods14. The article 3 of the Vienna convention clearly highlighted the norms related to the supply of goods in a legal and ethical manner amid two parties in the context of international sale of goods in business. The convention has also intended towards attaining a universal applicability for the law of sale of goods in the international platform. Focus has also been levied on the Vienna Convention to make easy and simple regulations so that its applicability can increase amid wide range of individuals and companies associated with the approach of international sale of goods and services law15. However, on a critical viewpoint, there are certain factors of the Vienna convention that raise questions over the universality and the applicability of the law governing sale of goods and services in a widespread manner altogether. This holds resemblance with the fact that various important factors relating to international Sale of Goods Act were not addressed within the Vienna convention, which further impacted the generalisability of the outcomes of the convention one way or the other. In this regard, a few of the aspects including cost, insurance and freight along with free on board equipment were less prevalent within the convention, which further hindered the formation of universally laws and regulations concerning international sale of goods and services. The convention has also designed few of the norms of sale of goods that are further regarded as cornerstone in the domain of international trade and business. The convention is believed to have attended by some of the major delegates from different parts of the world to reach into an ultimate conclusion regarding the norms and regulations of the Sale of Goods Act within the international marketplace16. However, it is often criticised that the convention has left various issues that remained unaddressed, which further impacted the generalisability of the results obtained from the convention in a widespread manner altogether. This aspect can further be justified from the fact that the convention took into concern the norms and the regulations related to the formation of contract in international sale of goods along with understanding the rights and duties of the buyers along with the sellers during international sale of goods and services. This lack of universality of the regulations formulated within the Vienna convention pertaining to Sale of Goods Act were criticised by a certain level17. Critical Analysis of the Statement: Exploring Literatures and Past Litigations The statement provided in this particular study mainly draws the inferences from the laws and regulations of the international sale of goods along with the study of Bridge in the book titled Benjamin’s Sale of Goods. Notably, international sale of goods and services is widely prevalent within the globalised present day environment. This involves cross-border trades with the intention of obtaining profits or expanding business units in any particular unexplored marketplace. It is often observed that the norms developed within the Vienna convention has left out various important aspects of international sale of goods and services including c.i.f and f.o.b, which have been less prioritised. Within the statement, it is argued that the literature of Benjamins Sale of Goods endeavoured to mitigate the limitations of the convention by developing effective norms that are widespread and addressing the requirements for conducting better international sale of goods and services18. Contracts are amongst the integral parts of international business and trade. These are often recognised as legal bindings amid the involved parties that influences or motivates them to act in accordance with certain set predetermined norms. However, there are certain specific contracts especially in the UK, where the norms of sale of goods have extensive applicability. It will be vital to mention in this similar regard that the law of sale of good is are applicable only for those contracts that are formulated after the year 1894 in the UK. The norms also highlight the capacity of trade amid two parties for a particular period of time. The laws followed in the UK assert that the contracts in sale of goods are not applied for specific products, rather they their applicability varies for most of the products and services that are being traded. It is strongly believed that in order to enhance the generalizability of the rules and the regulations relevant to international sale of goods, proper and systematic contemplation of the issues is an important aspect, which needs to be taken into concern by the concerned authorities. This denotes that during the formation of the laws and regulations related to sale of goods within the international and domestic marketplace, each and every issue associated with the subject matter must be taken into concern with due significance. It is quite evident from the analysis and evaluation of the statement in the previous section of the study that there lay considerable differences between the rules and regulations of Sale of Goods Act formulated within the Vienna convention, Benjamins Sale of Good along with the laws and regulations that are being practiced in the UK. This difference can be justified from the prevalence of c.i.f and f.o.b in Benjamins Sale of Goods that could not be seen within the laws and regulations of Vienna Convention. Distinctions can also be witnessed in the rules made by judges in the UK in the past cases concerning the sale of goods in cross-border trade or domestic business. To have a better comprehension in this context, the case of Wimble, Sons & Co. V. Kosenbeeg & Sons can be taken into concern. It is a particular case relating to Sale of Goods Act, wherein the aspect of free on broad in international trade has been apparently described and taken into consideration while deciding the outcomes of the case. Within the case, it was clearly mentioned that, if any obligation regarding sea transit and free on board is not discussed within the contract, it is the duty as well as the liability of a seller towards the buyer to ensure proper settlement of the sea transit during buying or selling of goods through sea route19. The decision of the Judge i.e. Vaughan Williams made it clear that in contracts relevant to sale of goods, the aspect of f.o.b is quite important and must be present in the same during international or domestic trade. Contextually, the approach within the Vienna convention for not discussing the factors such as f.o.b, which is widely used in international trade and sale of goods, can further be criticised extensively20. The article of Zhou (n.d.) provided a comprehensive understanding about the differences prevailing between international sale of goods law and the regulations along with the rules formulate and practice by the legal authorities of the UK. Since the establishment of the International Sales of Goods (CISG) during the year 1980, its underlying differences with the English law similar to this aspect is been a subject of extensive debate. CISG is a particular set of legislative principles, which has been formulated by a group of seventy-seven delegates of countries from different parts of the world. The laws and regulations that were established under the CISG are applicable for both domestic and international trade and the same are being followed in the courts of various nations of the world. This aspect further depicts the importance of CISG as International Sale of Goods norms. Irrespective of the fact that the CISG has a widespread presence throughout the world, the legal authorities of the UK showed their respective concerns over the adoption of CISG within their business activities related to the selling of varied goods and/or services. This might be owing to the reason that the authorities within the nations were well aware of the fact that with the involvement of CISG in trade related activities of the UK, the domination of the country within the commercial laws and other legal domains will decline extensively. This attitude of the officials in the UK has certainly hindered the widespread success of the set of laws and norms formulated under the CISG. Furthermore, several member states of the Vienna convention also tend to select English law over the CISG because of the belief that the UK laws governing sale of goods are more universal than the latter i.e. CISG. This clearly portrays the differences prevailing amid the two forms of Sale of Goods law such as CSIG and norms of Benjamins Sale of Goods that are extensively practiced in the present day scenario21. Notably, a comprehensive understanding about the concept of Bill Of Lading and other facets of shipment have been discussed in the case of Pyeene Co. Ld. V. Scindia Navigation Co. Ld and Wimble, Sons & Co. V. Kosenbeeg & Sons which is often seen as a landmark litigation in the domain of Sale of Goods Act22 23. As per the analysis of the facts of this particular case, it can be ascertained that bill of lading, which is an important part of f.o.b contract, governs the liability and rights of the buyers in certain cases. One of such cases can be determined as damage of goods during sale of goods in the form of shipment from one part to the other. It is worth mentioning that the involvement of the third party is restricted in such scenario for ensuring proper practice of the rights of the buyers and sellers within the Sale of Goods Act. This also depicts the fact that within the domain of Sale of Goods, the importance of f.o.b contract could not be ignored. In this regard, the facts in the statement provided for this study can be discussed critically to have better understanding of the aforementioned scenarios. It has been comprehended from the study of the provided statement that the Benjamins Sale of Goods along with the norms practiced in the UK may act as effective tools in ratifying the loopholes of the Vienna convention regarding the international sale of goods. This especially includes important factors of Sale of Goods law such as c.i.f. and f.o.b that have little prevalence within the framed regulations under CISG. By analysing the laws prevalent in the UK, it is quite apparent that the Sale of Goods Act practiced within the nation are more generalised and preferred by the people as compared to the CISG developed and rectified in the Vienna convention from time to time. This aspect further depicts the provided statement to be justifiable by a certain level24. This facet can further be supported with the help of facts gathered from past litigations relevant to Sale of Goods law. The renowned case of N. V Handel MY. J Smits Import-Export v. English Exporters (London), Ltd provided a greater insight about buying and selling of goods between English firms with foreign companies as per the norms of the international Sale of Goods Act. As per the facts of the case, a particular company from Dutch was involved in selling goods to an English based company. However, the primary issue with this particular case is about the applicability of the UK law or the Dutch law in the process of dealing with the prevailing challenges that emerged while advocating the case. This further depicts lack of availability of generalised and universally accepted set of laws for selling goods during cross-border trade. This aspect can also justify the statement that shows the prevalent problems in international or overseas sale of goods law formulated by Vienna Convention. To acquire a detailed idea about the concept of international sale of goods and its diversity with the guidelines depicted in Benjamins Sale of Goods, the study of Coetzee (2013) is noteworthy and thus has been taken into concern for discussion. The study highlighted the concept of INCOTERMS and its difference with the CISG laws and norms. INCOTERMS are set of legal norms that have been formulated by International Chamber of Commerce (ICC). These particularly govern international sale of goods and services. The set of rules under this particular legislative guidelines deals with the responsibilities of the sellers and the buyers while involving in international trade of goods. As per the viewpoints of Coetzee (2013), though similar in context and content, there prevail certain stiff dissimilarities between INCOTERMS and CISG laws. This can be justified from the fact that the two could not be used in international trade activities synonymously to one another. However, at the same time, the article of Coetzee (2013) also depicted that there are certain loopholes in each of the set of laws mentioned under INCOTERMS and CISG laws, which further hinder wider applicability and generalisability of the same by a considerable extent. The similarity amid the two set of laws or legislations can be mainly determined in the form of trade terms used in formulating the same that includes delivery of goods, delegation of risks and other related aspects. It has been comprehended that INCOTERMS are frequently updated based upon the current trade scenarios and policies as compared to CISG. Correspondingly, the differences amid the two concepts can also be traced in the form of contractual agreements and implications that persist amid the two set of laws wherein INCOTERMS are found to be more reliable, accurate and widely acceptable in comparison with CISG. Hence, a comparative description has been presented with regards to the differences prevailing in the legislations related to sale of goods in various parts of the world. There are certain specific components of CISG that are intended to govern the sale of goods in domestic as well as international business markets. Apparently, analysis of varied secondary sources depicted that the CISG deals with components such as responsibilities related to delivery of goods from one party to the other, delivery time of goods after purchase and obligations that resemble with the conformity of goods among others. All these components that are provided under CISG intend to govern the approaches made by the business units and the individuals during sale of goods and services in cross-border trade. There are also certain obligations for the buyers that are also extensively depicted within the CISG rules and norms of international trade. In this regard, a few of the domains of responsibilities of the buyers that are being governed under the regulations of CSIG include payment, place along with the time of delivery to be adhered among others. However, in relation to this particular study, the rules of the CISG are deemed to provide less focus on depicting the contractual terms and obligations that exist within the Sale of Goods Act in the global business or trade world. It is quite apparent from the analysis of various secondary sources such as journals and literatures that the laws under CISG largely deal with the responsibilities of the buyers and the sellers during the activities of sales or purchases of goods from one party or other. This particular aspect has further resulted in hindrance for wider acceptance of the CISG laws and regulations and likewise criticisms have been emerged against the same. However, on the contrary, there are also certain strengths of the CISG laws that can further provide a contradictory viewpoint. This can be in the form of universality of the norms that can be equally adopted by the nations of the world while conducting the activities of sales of goods and/or services. The analysis of the provided statement clearly highlight that contractual terms related to sales of goods and services within the global market have been one of the key aspects of international trade. It is also amongst the most widely used terms in sale of goods context including c.i.f. and f.o.b. that are not present within the set norms of CISG formulated during the Vienna convention. This aspect further raised criticisms against the universal laws of overseas and domestic sale of goods and services. Contextually, the statement provided for this particular study can be considered as true and justified. As per the provided statement, since Benjamins Sale of Goods literature provides a complete picture relevant to the sale of goods and represents the implications of the rules mentioned for the business domain, it can be used to rectify the prevailing issues within CISG norms25. Hence, from the analysis of the study, the provided statement for this particular essay can further be regarded as justifiable to an extent irrespective of the advantages and prominence that prevail with the Sale of Goods law universally by the international authority. Conclusion Based on the above analysis and discussion, certain key facts and findings portray the impact of Benjamin’s Sale of Goods in ratifying the Vienna Convention on Contracts for the international Sale of Goods. Justifiably, trade and business between two individuals and nations are amongst the topics that attract the attention of the people from different parts of the world. This is because of the fact that trade and business amid two nations imposes certain positive impacts on the economic development of the host nations. Contextually in order to ensure proper and effective performance of this particular concept of sale of goods of business, various laws and regulations have been contemplated with regards to govern the sector business and trade sector for ensuring legality and ethicality of the same at large. Research suggested that by ensuring legal and ethical operations of the companies and/or individuals regarding the execution of sale of goods further result in better performance and efficiency of the entire process at large. In relation to the above context, a particular statement has been taken into concern for analysis. The statement mainly determined the need for the prevalence of Benjamins Sale of Goods in order to rectify the norms of the international sale of goods law and the regulations that are being practiced in varied parts of the UK. In this regard, it is to be affirmed that Benjamins Sale of Goods is a particular literature, which addresses and presents the norms of the sale of goods and services in the overseas market in an extensive manner altogether. It has been designed in a simplistic form wherein one can be able to find all the norms and implications of sale of goods in the modern day scenario. On the other hand, the international sale of goods and services, which is also acknowledged as the CSIG, is a set of laws that are universally applicable for the countries in different parts of the world that tend to make smooth execution of the sale of goods and services within their region in a legal and ethical manner altogether. Analysis of the varied secondary sources along with the understanding gained from the provided statement, it can be determined that the set of norms under CSIG does not contain certain key terminologies relating to overseas sale of goods and services, which further raises criticisms over the wider acceptability of the laws. In this regard, a few of the most prominent and widely used terms used in international sale of goods that are missing in case of CSIG include c.i.f. and f.o.b., which one way or the other impacts overall acceptability of the norms in a collective manner. Hence, owing to the completeness of the Benjamins Sale of Goods as a tool for conducting overseas sale of goods and services efficiently, it can be determined that this tool can indeed act as a replacement of ratifying the loopholes persistent within the CSIG formulated in the Vienna Convention. References Alejandro M. Garro, ‘Reconciliation of Legal Traditions in the U.N. Convention on Contracts for the International Sale of Goods’ [1989] Pace Institute of International Commercial Law. Attorney, Fred S. Steingold, Legal Forms for Starting & Running a Small Business. (Nolo, 2012). Alastair C.L. Mullis, ‘Termination for Breach of Contract in C.I.F. Contracts Under the Vienna Convention [1] and English Law; Is There a Substantial Difference?’ (2004) Pace Law School Institute of International Commercial Law accessed 28 January 2015.   Allison E. Butler, ‘Performance and Obligations under the CISG, [2007] Aspen Publishers, 2. Bourne Nicholas, Principles on Company Law. (Routledge, 1998). Committee on Japan, ‘Global Economy, Global Technology, Global Corporations’, National Academies Press, 1998. C. Shaepe & Co., Limited V. Nosawa & Co [1917] 1915 C. 3510. Jill Poole, Casebook on Contract Law. (Oxford University Press, 2012). Judge Stephen, Q & A: Company Law 2008 and 2009. (Oxford University Press, 2008). Juana Coetzee, ‘The Interplay Between INCOTERMS And The CISG’ [2013] Journal of Law & Commerce, 32, 1. Kevin Bell, ‘The Sphere of Application of the Vienna Convention on Contracts for the International Sale of Goods’ [1996] Pace International Law Review, 8, 1. Kwei Tek Chao And Others (Trading As Zung Fu Co). V. British Traders and Shippers Ld. N. V. Handelsmaatschappij J. Smits Import-Export, Third Party [1954] 1935 C. No. 1245. Morse Geoffrey, Partnership Law (Oxford University Press, 2010). Michael G. Bridge, Benjamins Sale of Goods (Sweet & Maxwell, 2012). Michael G. Bridge, The Sale of Goods (Oxford University Press, 1998). Mantziaris Christos and Martin D. David F, Native Title Corporations: A Legal and Anthropological Analysis. (Federation Press, 2000). Michael Bridge, ‘A Law for International Sale of Goods’ [2014] Heinonline, 37. N. V Handel MY. J Smits Import-Export v. English Exporters (London), Ltd [1957] 1 Lloyds Rep. 517 (McNair J). Petar Sarcevic and Paul Volken, The International Sale of Goods Revisited (Kluwer Law International, 2001). Pyeene Co. Ld. V. Scindia Navigation Co. Ld [1954] 14 & 15 Geo. 5, c. 22. Philip Hackney, ‘Is the United Nations Convention on the International Sale of Goods Achieving Uniformity?’ [2014] Louisiana Law Review, 75, 2. Roach Lee, Company Law Concentrate: Law Revision and Study Guide. (Oxford University Press, 2013). United Nations, ‘United Nations Convention on Contracts for the International Sale of Goods’ [2010] United Nations Publication, 14. Wimble, Sons & Co. V. Kosenbeeg & Sons [1893] 56-57 Vict. c. 7. Qi Zhou, ‘CISG Versus English Sales Law: An Unfair Competition’ [No Date] SSRN, 41. Read More