A Study on a Global Jurisdiction and Judgments Convention

International civil and commercial litigation practice often faces the problem of lacking a global jurisdiction and judgments convention. As such, this book seeks to explore the deep conflicts between the US and the EU regarding jurisdictional issues and identify the true hurdles in reaching a global jurisdiction and judgments convention at The Hague. Is specifically includes:  A critical examination of the domestic jurisdictional systems of the two main players at The Hague, ie the US and the EU  A analysis on the respective advantages and disadvantages of the two systems  A revelation of the confrontation and the real difficulties at The Hague This book concludes with an exploration of the ideal model and possible way ahead (i)adopting predictable hard-and fast rules with moderate discretion being given to judges and (ii)that general jurisdiction should stand on an equal footing with special (specific)jurisdiction.