This study attempts to compare the various concepts which have been developed under U.S. and German law, focusing in particular the interpretation of fraud and the prerequisites for injunctive relief. Comparative analysis of case law, statutory provisions and corresponding commentaries will illustrate that although evolved out of different legal backgrounds the results show only minor deviations, a phenomenon which might support the hypothesis that instruments developed by practitioners to serve international commercial needs tend to give birth to uniform internationalized legal treatment.
Mahler, Dirk H., "Fraud and Injunctive Relief in International Standby Letter of Credit Transactions: A Comparative Study" (1984). LLM Theses and Essays. 115.