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.
Buttin, Sandrine, "Multinational Corporations Facing the Varying Concepts of Jurisdiction : "forum non-conveniens", Contrasts between the Anglo-American and the European Law Systems" (2002). LLM Theses and Essays. 21.