Comparative Analysis of Copyright Regimes in Nigeria, the United States of America and France (Published)
This paper deals with a comparative analysis of the copyright regimes Nigeria, the United States of America (U.S.) and France with a view to identifying impart areas from which to derive lessons. The United States is chosen because it is one of the most developed economies where the copyright industry has thoroughly developed to add to the country’s GDP. It has its copyrights roots in the common law, same as Nigeria. France is chosen because, it is a country which is also advanced in copyright development-the place of birth of the first international copyright treaty, the Berne Convention. This is added to the fact that France is a Civil law country and will offer interesting areas of comparison to the common law system.
Keywords: Comparative Analysis, France, Nigeria, United States of America, copyright regimes
The Dance of the Deal Exploring Culpa in Contrahendo and ECJ Jurisprudence (Published)
Culpa in contrahendo, also known as pre-contractual liability, is an essential legal doctrine that regulates the behavior of parties during contract formation and negotiation. In the European Union, culpa in contrahendo has been the subject of extensive jurisprudence by the European Court of Justice (ECJ), which has played a significant role in influencing its development and application in EU contract law. This paper provides an overview of culpa in contrahendo and its development, as well as an analysis of the ECJ’s case law on the doctrine. Subsequently this paper examines important ECJ decisions and evaluates the efficacy of culpa in contrahendo in EU contract law. In addition, the paper examines the practical application of culpa in contrahendo and compares it to other legal doctrines including estoppel, unjust enrichment, and good faith. In comparison to these other doctrines, the advantages and disadvantages of culpa in contrahendo are highlighted. Ultimately, the paper asserts that culpa in contrahendo is a useful legal concept for regulating pre-contractual behavior, despite its restricted applicability and dependence on a fault-based approach, which hinders its efficacy.
Keywords: Comparative Analysis, European court of justice, contract law legal doctrines, culpa in Contrahendo, pre-contractual liability