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A Comparative Analysis of US and English Contract Law ...
International In-house Counsel Journal Vol. 9, No. 33, Autumn 2015, 1 International In-house Counsel Journal ISSN 1754-0607 print/ISSN 1754-0607 online A Comparative Analysis of US and English Contract Law Interpretation and Implied Terms ANDREW TAYLOR General Counsel, Hesco Group ABSTRACT Contractual disputes frequently arise out of disagreements between commercial parties around ambiguous or incomplete contractual terms. Negotiating parties will seek to incorporate the terms of their commercial arrangement within a written contractual instrument that is comprehensive and unambiguous. Often, however, contracts are: 1) agreed under commercial pressure; 2) made between parties of unequal bargaining power; or 3) between parties dealing on cross-border transactions using differing terminology and drafting techniques. International in-house counsel are consequently required to deal with a variety of contracts with different governing laws and a colourful mix of terminology and drafting.
Comparative Analysis of US and English Contract Law 3 CONTRACT INTERPRETATION English law The leading authority on the principles that the English Courts will adopt ...
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