Penn State International Law Review


The United Nations Convention on Contracts for the International Sale of Goods aspires to the role of a transcendent uniform law. In order to lend uniformity to international sales law, the Convention must reduce the necessity of resorting to domestic conflict rules to determine applicable law, and it must reduce forum shopping. The second section of this Comment is a brief history of the effort to unify international sales law. The third section is concerned with uniformity. The applicability of the Convention with regard to both forum shopping and reliance on domestic conflict rules will be discussed. Ratification procedures are then considered in light of their direct effect on uniformity. The fourth section compares makor provisions of the Convention with domestic American law of contract formation. This section catalogs similarities and differences of the Code and Convention so that demands of the Convention can be anticipated.