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Homeward Trend and Lex Forism in International Sales Law

Author: Franco FERRARI

Type: Article

ref: 32009333-352

N0:3 of 2009

Pages: 333-352

This article shows why it is incorrect to assume that the coming into force of the United Nations Convention on Contracts for the International Sale of Goods Uniform has led to an international sales law that can be applied as one and the same in all the countries in which it has come into force. That assumption does not take due account of the fact that there are interpreters who read the Convention in light of their domestic law, even though they are not supposed do so, as reflected in the text of Article 7 of the Convention. And it is this "homeward trend" that this paper discusses and criticizes.