Terminology
Its three different names – conflict of laws, private international law, and international private law – are generally interchangeable, although none of them is wholly accurate or properly descriptive. The term conflict of laws is primarily used in jurisdictions of the Common Law legal tradition, such as in the United States, England, Canada, and Australia. Private international law (droit international privé) is used in France, as well as in Italy, Greece, and the Spanish- and Portuguese-speaking countries. International private law (internationales Privatrecht) is used in Germany (as well as Austria, Leichtenstein and Switzerland), Russia and Scotland.
Within the federal systems where legal conflicts among federal states require resolution, as in the United States and Australia, the term conflict of laws is preferred simply because such cases do not involve an international issue. Hence, conflict of laws is a general term to refer to disparities among laws, regardless of whether the relevant legal systems are international or inter-state. The term, however, can be misleading when it refers to resolution of conflicts between competing systems rather than "conflict" itself. The term private international law was coined by American lawyer and judge Joseph Story, but was abandoned subsequently by common law scholars and embraced by civil law lawyers.
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