Electronic Signatures in International Contracts
Electronic signature legislation seeks to facilitate e-commerce by providing an electronic equivalent to handwritten signatures in paper-based contracts. However, electronic signature legislation enacted in the past years in different jurisdictions has followed a dissimilar approach. In light thereof, this book analyzes the legal validity of electronic signatures in international contracts potentially subject to divergent electronic signature regulation. To this end, four major issues are addressed: the technological and legal concept of electronic signatures; the legal regulation of electronic signatures; the determination of the electronic signature legislation that will be applicable to an international contract; and, finally, the implications of applying one electronic signature law or another. The research covers the laws of Argentina, Germany and the United States of America as well as international conventions.
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B Electronic signatures
B The different legal approaches
Electronic signature legislation
B Legal framework of electronic signatures in Germany
B Argentine Digital Signature Act
B United Nations Convention on Contracts for the International Sale
Convention on the Law Applicable to Contractual Obligations
E InterAmerican Convention on the Law Applicable to International
B German law
Electronic signatures and international contracts
68th Edition applicable law Argentine Civil Code Argentine Digital Signature Argentine law Article Burgerliches Gesetzbuch certification-service-provider choice of law CISG Codigo Civil Commission on International Communications in International comply Conflict of Laws contracting parties Derecho Internacional Privado determine digital certificate Digital Signature Act domicile Droit International Prive E-Sign Electronic Commerce Electronic Communications electronic document electronic form electronic signature legislation Electronic Signatures Directive Electronic Transactions European Union foreign electronic signatures formal requirements formal validity Group on Electronic handwritten signatures International Contracts International Sale International Trade Law Internet issued Kommentar zum Burgerlichen law applicable Law on Electronic legal requirement legal system lex causae licensed certifier marginal number Munchener Kommentar Palandt place of performance private key public key cryptography public key infrastructure qualified electronic signatures Rome Convention Section 11 EGBGB Section 126a session signed statute types of electronic UETA UNCITRAL Model Law UNIDROIT Principles United Nations Commission United Nations Convention Volume