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the issue I want to talk about are the rules of jurisdiction in the European Union those rules are established by something known as the Brussels one regulation and to see why this was something that the European Union thought was necessary to regulate at the EU level we need to go back to the whole idea that lies under the Brussels one regulation that is to make it easy to enforce judgments from one member state in another member states courts for example if you've gotten judgment in France it should be fairly easy to get that judgment enforced in the UK the idea behind that's pretty simple if you can't enforce judgments in other member states then you're going to be reluctant to do business with people from other member states so the idea of a whole idea behind the European Union is that people should be just as willing to buy goods from France as they are from the UK if they live in the UK and if people cannot enforce judgments they'll be reluctant to do that so the main goal here is to say to courts in France and England you can trust judgments that were interred in France the same as if they were interred in England and you can enforce them just as easily but if that's your goal there's a problem because historically the courts in member states applied very different rules to decide which cases they could take jurisdiction over and furthermore in a lot of those jurisdictions other jurisdictions regarded their rules as exorbitant tour is outrageous and they therefore would not enforce judgments rendered by those other courts now give you some examples of how that worked out in practice France the first example the favorite but of complaints by the English France has a rule still has this rule that says that French courts can take jurisdiction over any case in which the plaintiff is French even if it has nothing to do with France and if nobody has ever been in for for example let's say a French tourist gets involved in an automobile accident in California and is seriously injured now the defendant of California driver may have never even been to France but under the fridge law a French the French plaintiff can go back home sue the California person for this automobile accident that took place in California and the California residents going to have to come to France to defend the case most other jurisdictions regard that is pretty outrageous that that a french court can take jurisdiction over a case just because the plaintiff happens to be French indeed they only have to be a citizen of France they don't even have to live in France so this California automobile accident could have involved a French citizen who hadn't lived in France for dozens of years but still was entitled to sue in France and to put the defendant to the expense of coming to France to defend the claim so that's one example second example German law which has been changed recently but until recently the German rule was that if you own property in Germany you could be sued in Germany for anything so there was a notorious case involving a French skier who left some underwear in a hotel room in Germany and somebody wanted to sue him in Germany and so they said ok he owns this underwear which he left in a hotel room in Germany therefore we can sue him in Germany even though the case has nothing whatsoever to do with Germany and even though the amount that he's being sued for is worth way more than the value of the underwear and furthermore he couldn't avoid this by saying look you can keep the underwear I just don't want to go to Germany to to hear the case well again other countries would regard that particular assertion of jurisdiction as outrageous and would refuse to enforce judgments and now a third example now to be fair i'll pick up on one where the english do something outrageous and that is the english rule is that as long as you are served with process you know in the in England you can be sued in England in a very famous case called the Maharani of baroda case the dispute was over a the genuineness of a picture that the plaintiff had purchased at an art gallery in Paris but she wanted to sue in England for various reasons and so while the defendant was at the Ascot horse races a very famous set of horse races that are held in the UK every year the plaintiff caused him to be served with process and so now he was being sued in England in the English Court said that's fine he was in England and if he served with process in England he can be forced to litigate in England over a dispute that has nothing to do with England neither party lived in england and the painting was bought in france it would be governed by french law nonetheless the english rule was the case could proceed in england and again other countries consider that outrageous so because of this because every country had some jurisdictional rules that other countries didn't like and would refuse to enforce the idea behind the Brussels regulation is we need to first regulate when courts can take jurisdiction so that afterwards we can be willing to enforce their judgments so instead of using these national rules of jurisdiction that most people consider outrageous we will agree on a common set of reasonable rules of jurisdiction and agree only to use those but there's an important qualification to that and that is that while the member states of the European Union agreed not to use these outrageous rules they only agreed not to use them against each other and that is the subject of continued controversy with respect to people outside the EU as far as how the EU jurisdictional rules work that's just one example of the kinds of issues we address in the module that I teach on international business transactions you