Multinational corporations facing the varying concepts of jurisdiction : "forum non-conveniens", contrasts between the Anglo-American and the European law systems

This thesis compares the rules of jurisdiction applicable to multinational corporations within two legal systems. The Anglo-American system favors forum non conveniens, whereas, the European applies European Regulation (EC) No. 44/2001. The difference between the two approaches permits litigants to practice forum shopping. The focus of the paper is to give an overview of the two approaches and to contrast them.