This Article explores the different approaches taken by the academic and judicial communities of Germany and the United States in their respective attempts to derive the optimal legal policy to deal with the multinational enterprise phenomenon. It attempts to assess the success of the Private International Law method as applied in most European countries by examining whether its criteria are operational and a reflection of economic reality. The Article also analyzes whether application of such criteria ensures the enforcement of the policies of the forum. It concludes by questioning whether the Private International Law approach is a viable alternative to the Public International Law approach.
Private International Law as a Means to Control the Multinational Enterprise,
19 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol19/iss3/1