This paper is superseded by a later draft of the complete book, which is available at http://ssrn.com/abstract=1711003.This is a working draft of a chapter in a book that introduces and compares civil justice systems in the United States, Germany and Korea. It addresses how the hypothetical...

The chapter “Applicable Law” of the International Law Association’s Guidelines on Intellectual Property and Private International Law (“Kyoto Guidelines”) provides principles on the choice of law in international intellectual property matters. The Guidelines confirm the traditional...