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Journal Erasmus Law Review x Year 2012 x

Helmut Heiss
Dr. iur. (University of Innsbruck), LL.M. (University of Chicago); Professor of Law (University of Zurich); Chairman of the Project Group on a Restatement of European Insurance Contract Law; of counsel, gbf attorneys-at-law, Zurich.

Isabelle Bambust
Researcher, University of Ghent.

Albert Kruger
Judge of the High Court of South Africa, Professor Extraordinary in Roman Law, History of Law and Comparative Law at the University of the Free State.

Thalia Kruger
Lecturer, University of Antwerp, Honorary Research Associate, University of Cape Town. This research was supported by the National Research Foundation of South Africa.

Christoph A. Kern
Dr. Christoph A. Kern, LL.M. (Harvard), professor, chair of Private Law, Private International Law, Comparative Law and Procedural Law at EBS Law School, Wiesbaden. The author wishes to express his gratitude to Maître Anne-Caroline Urbain, LL.M. (Harvard), admitted to the bars of Paris and New York, for her support in researching the current situation in France, as well as PD Dr. Alexander Brunner, Commercial Judge, Zurich, for his support in researching the situation in Switzerland. Remaining errors are the sole responsibility of the author.

Simone Glanert
Senior Lecturer in French and European Comparative Law, Kent Law School, Eliot College, Canterbury, Kent, CT2 7NS, UK; S.Glanert@kent.ac.uk. I presented early formulations of this argument at the RELINE Network for Interdisciplinary Studies in Language and the Law Seminar, Faculty of Law, University of Copenhagen, on 25 October 2011; at the Faculté de Droit, Université de Montréal, on 27 January 2012; at the 4th Annual Meeting of the Irish Society of Comparative Law (ISCL), Faculty of Law, University of Cork, on 2 March 2012; and at the Faculté de Droit, Université de Grenoble, on 22 March 2012. I am grateful to Anne Lise Kjær, Jean-Franois Gaudreault-DesBiens, Bénédicte Fuller-Sage and David Dechenaud for their kind expression of interest in my work and generous invitations.
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