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Comparative Product Liability

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Preface
The Fundamentals of Product Liability	p. 1
European Harmonization	p. 17
European Product Liability Directive	p. 29
Product Liability in the United Kingdom: Contract	p. 51
Product Liability in the United Kingdom: Negligence	p. 69
United Kingdom's Consumer Protection Act 1987	p. 89
France: Europe's Loser in the Product Liability Stakes?	p. 101
Germany: Minimalist Implementation of the Directive	p. 123
Scandinavia: The Insurance Solution	p. 147
Product Liability in the Rest of Europe: The Impact of the Directive	p. 175
Harmony in Europe?	p. 195
United States: Birthplace of the Product Liability Phenomenon	p. 201
United States: The Product Liability Reform Debate	p. 227
Canadian Product Liability: The Middle Ground	p. 247
Australia: Radical Thinking - Traditional Reform	p. 279
New Zealand's Accident Compensation Approach to Product Liability	p. 291
Product Liability Compensation and Harmonization: A Personal View	p. 307
Index	p. 325
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