Anmerkungen:
In: GROUPES INTERNATIONAUX DE SOCIÉTÉS: NOUVEAUX DÉFIS, NOUVEAUX DANGERS, X. Boucobza, G. Mecarelli, eds., Economica, Paris, 2007
Beschreibung:
Class actions are still a specificity of U.S. law and allow individual claimants to represent others, in a similar situation, at the occasion of a lawsuit brought against a same defendant. Several multinationals incorporated outside the United States are more and more frequently facing class actions procedures. This article aims at assessing the risks for foreign multinationals to be successfully involved in a U.S. class action procedure. Although, the United States are traditionally known for the extraterritorial application of their laws and the very wide jurisdiction of their courts, one notices an attempt to bring together the legal systems concerned by taking into consideration the possibility of recognition of the class action judgment to come. Therefore, the author addresses the issue whether class actions judgments can be recognised in legal systems that ignore class action-like procedures. Discussing the issue mainly from a French law perspective, the author is of the opinion that recognition of U.S. class action judgments is more likely than not