Recent Japanese cases concerning international jurisdiction illustrate a convergence of two distinct legal approaches to the treatment of jurisdictional issue--a rule-based, inflexible approach in Continental European countries and a standard-based, flexible approach in the United States. Japan's unique framework, as explained in this Article, might provide a useful perspective to solve the difficult question currently imposed on the Hague Conference: How is it possible to achieve comprehensive harmonization of the jurisdictional systems of the world?
Jurisdictional Theory "Made in Japan": Convergence of U.S. and Continental European Approaches,
37 Vanderbilt Law Review
Available at: https://scholarship.law.vanderbilt.edu/vjtl/vol37/iss5/2