Limitation of Liability - A Comparative Study

This book deals with incorporation interpretation and validity of liability disclaimers (LD) in unilaterally drafted B2B-standard terms in DK (civil law) England (common law) and United States of America (mostly common law). I mainly analyze the remedy of damages. Other clauses may in reality function as LDs why the same judicial methods as a main rule apply in regards to these clauses also. All three countries have similar approaches however there are differences a lawyer should be aware about when drafting contracts in these countries and also on how a lawyer should deal with these clauses in matters of dispute.