The Localization of American Traditional Conflicts Law and its Implications for China
XU Qing-kun (School of Law, Shandong University, Jinan 250100, P.R.China)
The process of the localization of American traditional conflicts law has experienced two characteristic phases. Story introduced the International Comity Doctrine of Huber with the guide of his jurisprudence of natural law, and established the basis of American conflicts law. During the period when formalism was popular, Beale developed American conflicts law with the form of Restatement of the Law of Conflict of Laws (First), based on his theory of vested rights. The development of China's Private International Law should fully absorb the useful experience of the localization of American conflicts law by introducing foreign rules and theories and innovate them on the basis of its situations, and by inheriting traditions and developing them with in accordance with changes of the times.
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