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Tort Obligations and Conflict of Laws in the USA and the EU

Student: Abdullaev Abdul

Supervisor: Irina V. Getman-Pavlova

Faculty: Faculty of Law

Educational Programme: Private International Law (Master)

Year of Graduation: 2019

The paper is devoted to the issue of cross-border torts regulation in the USA and the EU. The author deals with the background of modern approaches to the issue of cross-border tort regulation in the EU and the USA, analyses condition of modern regulation in this area of law, gives comparative analysis of the both jurisdictions, analyses the potential ways of development of the existing regulation. The jurisdictions of the USA and the EU were chosen for the following reasons: it is said that the regulation of the both jurisdictions have similar tendencies, the author shows the interaction of the both jurisdictions. The general subjects of research were: the Rome II Regulation (EC) № 864/2007, private international law of European countries on the issues of torts, the First Restatement of Conflict of Laws (1934), the Second Restatement of Conflict of Laws 1971, statutory regulation of cross-border torts in the US, the US caselaw.

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