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==== Convergence of common law and civil law ==== The contrast between civil law and common law legal systems has become increasingly blurred, with the growing importance of [[jurisprudence]] (similar to [[case law]] but not binding) in civil law countries, and the growing importance of [[code law|statute law and codes]] in common law countries. Common law countries are increasingly adopting codes, similar to civil law systems, in areas such as [[Bankruptcy in the United States|bankruptcy]], [[intellectual property]], [[Competition law|antitrust]], banking regulation, securities, and tax law.<ref name="Best of Both">{{cite web |last=Funken |first=Katja |date=July 2003 |title=The Best of Both Worlds - The Trend Towards Convergence of the Civil Law and the Common Law System |url=https://papers.ssrn.com/sol3/papers.cfm?abstract_id=476461 |access-date=29 November 2024 |website=SSRN|ssrn=476461 }}</ref>{{rp|pages=|style=AMA|page=5}} In the United States, the [[Uniform Commercial Code]] (UCC) is an example of a codified framework governing various aspects of commercial law.<ref name="Best of Both" />{{rp|pages=|style=AMA|page=6}} Widely regarded as one of the most significant developments in American law, the UCC has been enacted, with some local variations, in all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands.<ref>{{Cite web |title=Uniform Commercial Code |url=https://www.uniformlaws.org/acts/ucc |access-date=2024-11-29 |website=www.uniformlaws.org |language=en |quote="The Uniform Commercial Code (UCC) is a comprehensive set of laws governing all commercial transactions in the United States. It is not a federal law, but a uniformly adopted state law. Uniformity of law is essential in this area for the interstate transaction of business. Because the UCC has been universally adopted, businesses can enter into contracts with confidence that the terms will be enforced in the same way by the courts of every American jurisdiction. The resulting certainty of business relationships allows businesses to grow and the American economy to thrive. For this reason, the UCC has been called 'the backbone of American commerce.'"}}</ref><ref>{{Cite web |title=Uniform Commercial Code (UCC) {{!}} Duke University School of Law |url=https://law.duke.edu/lib/research-guides/ucc/ |url-status=live |archive-url=https://web.archive.org/web/20240726101637/https://law.duke.edu/lib/research-guides/ucc/ |archive-date=2024-07-26 |access-date=2024-11-29 |website=law.duke.edu |language=en |quote="The Uniform Commercial Code (UCC), a comprehensive code addressing most aspects of commercial law, is generally viewed as one of the most important developments in American law. The UCC text and draft revisions are written by experts in commercial law and submitted as drafts for approval to the National Conference of Commissioners on Uniform State Laws (referred to as the Uniform Law Commissioners), in collaboration with the American Law Institute. The Commissioners are all attorneys, qualified to practice law, including state and federal judges, legislators and law professors from throughout the United States and its territories. These quasi-public organizations meet and decide whether to endorse the drafts or to send them back to the experts for revision. The revision process may result in several different revisions of the original draft. Once a draft is endorsed, the Uniform Law Commissioners recommend that the states adopt these rules. The UCC is a model code, so it does not have legal effect in a jurisdiction unless UCC provisions are enacted by the individual state legislatures as statutes. Currently, the UCC (in whole or in part) has been enacted, with some local variation, in all 50 states, the District of Columbia, Puerto Rico, and the Virgin Islands."}}</ref> An example of convergence from the other direction is shown in the 1982 decision ''Srl CILFIT and Lanificio di Gavardo SpA v Ministry of Health'' ({{ECLI|ECLI:EU:C:1982:335}}), in which the [[European Court of Justice]] held that questions it has already answered need not be resubmitted. This showed how a historically distinctly common law principle is used by a court composed of judges (at that time) of essentially civil law jurisdiction.
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