Abstract
Global trade and intercontinental tourism are on the rise in today’s world. This, in turn,
leads to more cross-border law suits. Inevitably, jurisdictions will be confronted with legal
concepts that are unknown in the host forum. This contribution investigates whether, and
to what extent, punitive damages judgments originating in the United States can be enforced
against the assets of a defendant in a number of selected Member States of the EU.
More specifically, the article explores the possibilities of enforcing American punitive damages
judgments in five EU countries, namely Germany, Italy, Spain, France and England. This
comparative analysis reveals that the case law in these selected countries is relatively divergent
as to the stance adopted towards foreign punitive damages, resulting in different degrees of
acceptance of this legal remedy.
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