Anspruchskonkurrenz im internationalen Privatrecht

In most cases there is more than one cause of action which provides for legal consequences that are generally apt to support the plaintiff's claim. Thus every legal system contains - mostly unwritten - rules according to which the judge has to decide to what extent different causes of action can be accumulated for the plaintiff's benefit. If the basis for claims from different legal systems intersect, some of these rules may contradict each other. Ullrich Spelsberg-Korspeter examines how to deal with the risk presented by these contradictions. Based on his evaluation, which includes the new Rome II regulation, the author provides a critical assessment of the method of the accessory connecting factor rule frequently advocated in professional literature.