The course presents new methodological approaches to European, German and US- American Conflict of Laws posed by an increasingly globalized world.

Recent case law of the US Supreme Court, the European Court of Justice and the German Federal Court will be discussed.

In modern societies individual interests are becoming more and more important, demanding private international law to no longer only determine the legal order closest connected to the respective case (via the traditional method of conflict of laws named “designation”), but to consider individual interests and substantive arguments as well. To cope with these current developments, private international law will have to strike a balance between individuals’ and states’ interests, while ensuring international consistency at the same time. The lecture aims at showing that these challenges can, however, be met, if the traditional method of designation was complemented by the methods of recognition and cognizance, i.e. the taking into consideration of foreign local and moral data.