The goal of this research is to state the current situation concerning products liability in the United States, the Federal Republic of Germany and more briefly, France and to compare the different systems. Emphasis will be given to the substantive laws, in particular to the new EC Directive and its adoption in the Federal Republic of Germany. Also, it will discuss the current German law, since this will be valid for all claims initiated before the enactment of the new ProdHaftG. Further, based on the previous analysis, it will be shown where a consumer is in the most favorable position to make out a claim against a foreign producer. Since the various parts of the chain of distribution are also subject to liability in products liability actions, their responsibility also will be described.
Baum, Lothar W., "Forum Shopping in Products Liability Actions: A Comparison Between the United States, France and Germany" (1988). LLM Theses and Essays. Paper 117.