US vs English Contract Law Similarities and Differences
Contracts often look simple on paper. One side promises to do something. The other side promises to pay or perform. The problem starts when the deal crosses legal systems.
US and English contract law share a common family tree. Both grew from the common law. Both value bargains, proof, and commercial certainty. Yet they do not treat every question the same way.
This article is general information, not legal advice. Contract disputes turn on the facts, the wording, and the governing law.
Both systems start from the same basic idea
The core idea is the same in both systems. A contract is a legally binding promise or set of promises. The law asks whether the parties made a deal that the courts should enforce.
That shared starting point matters. It explains why US and English contracts often use similar language. It also explains why courts in both systems ask many of the same first questions.
A court will usually ask:
Did the parties reach an agreement?
Did each side give something of value?
Did the parties intend legal consequences?
Are the terms clear enough?
Did anything make the deal invalid?
What remedy should follow if one side breaks the contract?
The answers can differ. The questions are still close.
Agreement needs offer and acceptance
Both systems use the idea of offer and acceptance.
An offer is a clear proposal to enter a contract on stated terms. Acceptance is agreement to those terms. If one side changes the terms, that usually counts as a counter-offer, not acceptance.
For example, a supplier offers to sell 1,000 parts for £10 each, delivery next month. The buyer replies, “Accepted, but delivery must be this week.” That reply is not a clean acceptance. It changes a key term. It becomes a new proposal.
English law is strict about this classic model. US law often starts in the same place, but it can be more flexible in sale of goods cases. The Uniform Commercial Code, a model set of rules used by US states for commercial goods transactions, allows some contracts to form even when written forms do not match perfectly. That produces a practical result in some disputes. The law may recognise a deal first, then work out which terms apply.
English law can also recognise conduct. If both sides act as if a deal exists, the court may find one. Yet English courts often pay close attention to whether there was a clear acceptance of the actual terms.
Consideration remains central
Both systems also use consideration. This means each side must give, do, or promise something of value.
Payment is consideration. So is delivery of goods. A promise not to sue can also be consideration, if the claim has a real basis.
English law still treats consideration as a key requirement for most simple contracts. A promise made for nothing is usually not enforceable unless made by deed. A deed is a formal signed document that follows special rules. It does not need consideration.
US law also uses consideration, but it has wider safety valves. One major example is promissory estoppel. This means a promise may sometimes be enforced if someone reasonably relied on it and would suffer unfair harm if the promisor could walk away. English law recognises related ideas, but it uses them more narrowly. In English law, promissory estoppel usually acts as a shield, not a sword. That means it often stops a party from insisting on strict rights, rather than creating a new claim on its own.
This difference can matter in settlement talks, informal promises, and business relationships where people rely on assurances before final papers are signed.
Intention to create legal relations matters
English law asks whether the parties intended to create legal relations. In business deals, the court usually presumes they did. In domestic or social arrangements, the court usually presumes they did not.
US law also looks at intent, but it does not always treat it as a separate formal requirement in the same way. The focus is often on whether the words and conduct show a binding bargain.
In practice, both systems care about context. A casual promise over dinner will not be treated like a signed supply contract. A detailed written agreement between two companies will usually be treated as legally serious.
Certainty is required
A contract must be clear enough to enforce.
If the price, subject, timing, or work are too vague, a court may refuse to enforce the agreement. Courts do not want to write the deal for the parties.
The United States may show more flexibility where the parties clearly meant to contract. In sale of goods cases, the law may fill some gaps, such as a reasonable price or reasonable delivery time. English courts can also imply terms where needed, but they are cautious. They prefer to enforce the bargain the parties actually made.
This is why vague words can cause problems in both systems. Phrases like “fair price”, “suitable quality”, or “best efforts” can be useful, but they invite argument if not tied to facts, standards, or timing.
The biggest difference is the legal framework
The most practical difference is structure.
English contract law is largely unified for England and Wales. The same broad rules apply across that jurisdiction. Scotland and Northern Ireland have different legal systems, so “English law” should not be used as shorthand for the whole United Kingdom.
US contract law is more fragmented. Contract law is mainly state law. That means the rules can vary between California, New York, Texas, Delaware, and other states. Some federal law can affect contracts, especially in areas such as employment, consumer finance, securities, shipping, and government contracts. Yet the basic contract rules usually come from state law.
This creates a different drafting problem.
Under English law, a clause choosing “the laws of England and Wales” points to a largely single body of contract law. Under US law, a contract should name the state law that governs it. “US law” is usually not precise enough.
The role of legislation differs
Both systems use judge-made law and legislation.
English contract law has major statutes. Examples include:
Sale of Goods Act 1979
Unfair Contract Terms Act 1977
Consumer Rights Act 2015
Contracts (Rights of Third Parties) Act 1999
Misrepresentation Act 1967
These Acts sit alongside common law rules made by courts.
The United States also uses statutes. The clearest example is the Uniform Commercial Code. It is not federal law. Each state adopts its own version. Most states have adopted much of it, but details can vary.
This matters for goods contracts. A contract for the sale of goods in a US state may be affected by the Uniform Commercial Code rules as adopted in that state. A similar English contract may be affected by the Sale of Goods Act 1979, the Consumer Rights Act 2015, or both, depending on the parties and type of sale.
The United States has more state-level variation
State variation affects more than documents. It affects outcomes.
A clause valid under one state’s law may face limits under another state’s law. A non-compete clause, which restricts someone from working in a competing business, is a strong example. Some US states are far more hostile to these clauses than others. English law also restricts them, but it uses a reasonableness test rooted in restraint of trade principles.
Limitation periods also differ. A limitation period is the time limit for bringing a claim. In England, the usual period for a simple contract claim is six years from breach. For a deed, it is usually twelve years. In the United States, limitation periods vary by state and contract type.
That makes local legal advice more important in US contract disputes.
Court systems affect strategy
England and Wales have a central court system. Many commercial disputes go through specialist parts of the High Court, including the Commercial Court. Decisions from higher courts bind lower courts.
The United States has both state courts and federal courts. A contract dispute may be heard in state court. It may be heard in federal court if certain conditions are met, such as parties from different states and enough money at stake, or a federal legal issue. Federal courts may still apply state contract law.
This can affect cost, timing, choice of forum, and litigation tactics.
Two contracts with similar wording may face different paths because one is governed by English law and heard in London, while another is governed by New York law and heard in a US federal court.
Choice of law needs precision
Commercial contracts often include a governing law clause. This says which legal system controls the contract.
A strong clause says something like:
“The contract is governed by the laws of England and Wales.”
Or:
“The contract is governed by the laws of the State of New York.”
A weak clause says only “governed by US law” or “governed by UK law”. Those phrases create uncertainty. The United States has many state laws. The United Kingdom contains more than one legal system.
A separate court clause, often called a jurisdiction clause, says which courts can hear disputes. The governing law and court clause should work together. They are not the same thing.
A contract can choose English law but require disputes to be heard elsewhere. That may be possible, but it can add cost and complexity. A court may need expert evidence on foreign law.
The same applies the other way round. A US court may need evidence about English law if the contract chooses English law but the case proceeds in the United States.
A quick comparison of core features
Issue | English law | US law |
Main source of contract law | Common law plus statutes for England and Wales | Mostly state law, influenced by common law and state statutes |
Goods contracts | Sale of Goods Act 1979 and consumer law where relevant | Uniform Commercial Code as adopted by each state |
Need for consideration | Strong requirement unless the contract is a deed | Strong requirement, with broader reliance-based exceptions in some cases |
Good faith | Limited general role, stronger in specific contexts | Wider role in many contracts, especially under goods law |
Court structure | More unified for England and Wales | Split between state and federal courts |
Contract interpretation | Strong focus on objective meaning and wording in context | Varies by state, often more open to outside evidence |
Punitive damages | Rare in contract claims | Rare for pure contract claims, but more possible where another wrong is involved |
Formation and interpretation do not always match
The hardest disputes often start with a simple issue. One side says there was a deal. The other side says there was not. Or both sides agree there was a deal, but disagree over what it means.
This is where differences between the systems become sharp.
For anyone needing a Comparative Analysis: US vs. English Contract Law Explore the similarities and differences between US and English contract law systems, formation and interpretation are the first places to look.
English law gives weight to the written bargain
English law places strong weight on the language the parties used. Courts read the contract as a whole. They ask what a reasonable person, with the background known to both parties, would understand the words to mean.
This is an objective test. The court does not ask what one party privately meant. Private intention does not control the meaning of the contract.
Context matters, but it has limits. English courts will not usually use pre-contract negotiations to change the meaning of clear words. They may look at background facts, the commercial setting, and the purpose of the contract. They remain careful not to rewrite the bargain.
This helps certainty. Parties can rely on the words they signed. The cost is that a party may be stuck with wording that does not match what they hoped it meant.
US law can be more open to outside evidence
US courts also start with the wording. Yet many states are more willing to look at outside evidence. This includes negotiations, trade usage, course of dealing, and how the parties performed after signing.
A trade usage is a practice common in a particular trade. A course of dealing is a pattern from earlier transactions between the same parties. Course of performance means how the parties acted under this contract after it began.
These ideas can affect the meaning of a contract in US law, especially under the Uniform Commercial Code.
For example, a supply contract may say delivery must be “prompt”. That word can be vague. A US court may look at prior deliveries between the parties or industry practice. An English court may also consider context, but it may be less willing to let external material dilute clear wording.
The difference is not absolute. US law varies between states. English law is not blind to background. The general pattern still holds. English law often values the final written text more strongly. US law may give more room to commercial practice and surrounding facts.
The parol evidence rule is stricter in name than in use
The parol evidence rule is a rule about outside evidence. It says that if parties put their complete deal in writing, earlier or side statements cannot usually change that written deal.
Both systems recognise the idea. It is often discussed more in US law.
In practice, the rule has many exceptions. Outside evidence may be allowed to show fraud, mistake, unclear wording, missing terms, or a separate side agreement. In US law, the number and reach of exceptions can make the rule less strict than it sounds.
English law reaches similar outcomes through rules on interpretation, misrepresentation, rectification, and implied terms. Rectification means correcting a written contract where it fails to record the parties’ actual agreed terms.
The point is simple. Written words matter in both systems. They matter a lot. Yet neither system treats a contract as a sealed box in every case.
Good faith plays a different role
Good faith means honest dealing and fair conduct. It does not mean being generous. It does not mean giving up a negotiated advantage.
US law gives good faith a wider role. Many US contracts carry an implied duty of good faith and fair dealing. This means a party must not act in a way that destroys the other side’s right to receive the benefit of the bargain. Under the Uniform Commercial Code, good faith also matters in goods contracts.
English law is more cautious. It does not recognise one broad duty of good faith across all commercial contracts. Good faith may apply where the contract says so. It may also appear in specific types of relationship, such as some long-term or relational contracts. Courts may imply duties of honesty or cooperation in certain cases. They will not lightly create a broad fairness rule.
This difference can change behaviour. A US party may argue that conduct was bad faith even if no clause was broken in a narrow sense. Under English law, that argument is harder unless the contract wording or relationship supports it.
Battle of the forms can lead to different answers
Many businesses trade using standard terms. One side sends a purchase order with its terms. The other sends an acknowledgement with different terms. Goods ship. Payment follows. Later, a dispute arises. Whose terms apply?
This is often called a battle of the forms.
English law often applies the “last shot” approach. The last set of terms sent before performance may win, if the other party’s conduct counts as acceptance.
US law, especially for goods, may take a different approach under the Uniform Commercial Code. A contract can form even where written forms differ. Some extra or different terms may become part of the contract, while others may be excluded. In many cases, conflicting terms are knocked out and replaced by default legal rules.
This can make a large difference. A liability limit, warranty term, or dispute clause may survive in one system and fail in the other.
The safest answer is not to rely on forms crossing in the dark. Get express agreement on the key terms before performance begins.
Contract terms, unfairness, and third parties can diverge
After formation comes content. What terms are in the contract? Which terms will the court enforce? Can a person outside the contract benefit from it?
Both systems give parties wide freedom to bargain. Both systems also impose limits. Those limits do not always sit in the same place.
Express terms and implied terms work in both systems
An express term is written or spoken as part of the deal. An implied term is not stated, but the law treats it as part of the contract.
English law may imply terms in fact or by law. A term implied in fact fills a gap in a specific contract. A term implied by law applies to a class of contracts. For example, sale of goods law can imply terms about quality and title.
US law also implies terms. State law and the Uniform Commercial Code can fill gaps. A sales contract may include implied promises about normal quality and fitness for a known purpose. Fitness means the goods are suitable for the buyer’s stated use.
Businesses often try to exclude implied terms. Both systems allow some exclusions, but not without limits.
Exclusion and limitation clauses face different controls
An exclusion clause tries to exclude liability. A limitation clause tries to cap liability.
English law closely controls these clauses through statute and common law. The Unfair Contract Terms Act 1977 applies to many business terms. It often asks whether a clause is reasonable. Consumer contracts face stronger protection under the Consumer Rights Act 2015.
English courts also interpret exclusion clauses carefully. Clear words are needed, especially for serious breaches or negligence.
US law also controls unfair or extreme clauses. The tools vary by state. Courts may refuse terms that are unconscionable. This means the term is so unfair, and the bargaining process so one-sided, that the court will not enforce it. Consumer laws can add further limits.
The practical difference is predictability. English law has well-known statutory reasonableness controls. US law can vary state by state, and consumer rules may differ more widely.
Penalty clauses are treated differently
A penalty clause imposes a payment or loss because of breach. A liquidated damages clause sets an agreed sum payable for breach. The legal issue is whether the sum is a fair pre-estimate or legitimate protection, or an unlawful punishment.
English law will not enforce a penalty. It may enforce a liquidated damages clause if it protects a legitimate interest and is not out of all proportion to that interest.
US law also rejects penalties. It generally enforces liquidated damages if actual loss would be hard to measure and the amount is reasonable in light of expected or actual harm. The exact test varies by state.
Both systems reject punishment in ordinary contract damages. The goal is compensation, not revenge.
This matters in delay clauses, service credits, early termination fees, and failed completion payments. If the sum is too harsh compared with the harm, it may fail.
Third party rights are not identical
The old common law rule was privity of contract. This means only parties to a contract can sue on it. If A and B make a contract to benefit C, C cannot usually enforce it unless the law allows an exception.
English law changed this through the Contracts (Rights of Third Parties) Act 1999. A third party can enforce a term if the contract says they can, or if the term appears to benefit them and the contract does not show a contrary intention.
Contract drafters often exclude the Act if they do not want third party rights.
US law has long recognised third party beneficiary rights in many states. If a contract was made to benefit a third person, that person may sometimes enforce it. The rules vary, but the concept is well established.
The result can be similar. The route differs. English law uses a clear statute. US law often relies on state common law principles.
Consumer law can override agreed terms
Both systems protect consumers more than commercial parties.
English consumer law is strong and centralised for England and Wales. The Consumer Rights Act 2015 sets rules on fairness, quality, digital content, services, and remedies. A trader cannot simply contract out of many consumer rights.
The United States also has consumer protection rules. They may come from federal law, state law, or both. The mix can be complex. Some states give stronger protection than others.
A clause that works in a business-to-business deal may fail in a consumer deal. This is true on both sides of the Atlantic.
For cross-border online contracts, consumer protection creates special risk. A business may choose English law or a US state law, but mandatory consumer rules may still apply where the consumer lives.
Remedies share a goal but differ in detail
When a contract is broken, the law asks what remedy fits. The usual remedy is money. Sometimes the court orders performance. Sometimes the contract ends. Sometimes a clause limits the result.
Both systems aim to put the innocent party in the position they would have been in if the contract had been performed. This does not mean every loss is recoverable.
Damages are mainly compensatory
Damages are money awarded for loss. Both English and US law usually award expectation damages. This means the benefit the injured party expected from the contract.
For example, a seller agrees to deliver goods for £50,000. The seller breaches. The buyer buys substitute goods for £58,000. The basic loss may be £8,000, plus reasonable extra costs, if proved.
Both systems require causation. The breach must cause the loss. Both systems also require proof. A court will not award guessed losses.
Both systems limit damages for remote losses. A loss is remote if it is too far removed from the breach. English law uses a well-known rule that losses must arise naturally or have been within the reasonable contemplation of the parties. US law uses similar principles under the idea of foreseeability.
Mitigation is required
The injured party must take reasonable steps to reduce loss. This is called mitigation.
If a buyer can obtain substitute goods at a reasonable price, they should not sit back and let the loss grow. If a contractor is wrongly dismissed from a project, they may need to seek other work where reasonable.
Mitigation does not require heroic action. It requires reasonable action.
This rule keeps damages tied to real loss. It also discourages waste.
Specific performance is exceptional
Specific performance is a court order requiring a party to do what they promised.
Both systems treat it as an exceptional remedy. Money is usually enough. Yet the details differ.
English courts may order specific performance where damages are not adequate. This can happen with unique goods, land, or certain long-term obligations. It is still discretionary. The court can refuse it if supervision would be hard or the order would be unfair.
US law also treats specific performance as exceptional, but it may be more readily available for land because each parcel of land is treated as unique. For ordinary goods or services, damages are usually the main remedy.
Courts are especially reluctant to force ongoing personal services. They do not want to compel a working relationship that has broken down.
Punitive damages are rare in contract
Punitive damages punish wrongdoers. They go beyond compensation.
English law rarely awards punitive damages in civil cases, and not as a normal contract remedy. US law is more familiar with punitive damages in some civil claims. Even there, they are usually not available for a pure breach of contract. They may become possible if the conduct also counts as a separate wrong, such as fraud.
This difference is often misunderstood. US law does not normally let a party recover punitive damages just because a contract was breached. The facts must support more than ordinary breach.
Misrepresentation can change the remedy
A misrepresentation is a false statement that leads someone to enter a contract. Both systems recognise remedies for it, but they organise them differently.
English law has a mix of common law and statute. The Misrepresentation Act 1967 can matter, especially for negligent misrepresentation. Remedies may include rescission, which unwinds the contract, and damages in some cases.
US law treats misrepresentation through state law. Claims may include fraud, negligent misrepresentation, or innocent misrepresentation depending on the facts and state rules. Fraud can open the door to wider remedies in some cases.
This area can create major differences because it sits at the boundary between contract and civil wrongs.
Termination rules need careful drafting
A breach does not always let the innocent party end the contract. Some breaches justify termination. Others only justify damages.
English law classifies terms in ways that affect termination. Breach of a condition usually permits termination. Breach of a warranty usually gives damages only. Some terms fall in the middle, where the effect of the breach matters.
US law uses different labels and state-specific rules. For sale of goods, the Uniform Commercial Code has detailed rules. Buyers may reject goods in some cases, but acceptance, cure, and notice rules can change the result. Cure means the seller gets a chance to fix the problem.
The safest drafting states when termination is allowed. It should cover notice, cure periods, consequences of termination, payment, return of property, confidentiality, and survival of key clauses.
Drafting choices decide many outcomes before a dispute starts
The legal differences matter most before anyone sues. Careful drafting can reduce risk. Poor drafting moves power from the parties to the court.
Cross-border contracts need precision. A contract linked to the United States and England should not rely on assumptions.
Choose the governing law clearly
A governing law clause should identify the exact system.
Use “laws of England and Wales” if that is the choice. Use the named US state if US law is chosen. Do not write “UK law” or “US law” unless a lawyer has a specific reason and a clear mechanism.
A governing law clause should sit near the dispute clause. The two should match the commercial plan.
If English law governs but New York courts hear the dispute, the court may need evidence on English law. That can add cost. The same issue arises if a London court hears a dispute governed by California law.
Choose the dispute forum with care
A forum clause says where disputes are heard. It may point to courts or arbitration. Arbitration is a private process where an appointed decision-maker decides the dispute. It can help with cross-border enforcement, confidentiality, and specialist decision-makers. It can also be costly.
Court clauses can be exclusive or non-exclusive. An exclusive clause says disputes must be brought in one place. A non-exclusive clause allows that place but may not prevent proceedings elsewhere.
The forum should match the parties, assets, language, governing law, and likely enforcement needs.
Match legal style to the chosen law
English law contracts often use detailed wording, but they may rely on common law concepts. US contracts often include longer lists and more express definitions because state variation and litigation style can drive detailed drafting.
Neither style is better in every case. The issue is fit.
If English law governs, do not import US wording without checking how English courts will read it. If a US state law governs, do not assume English drafting habits will produce the same result.
Words like “best endeavours”, “reasonable endeavours”, and “best efforts” can carry different weight. Even familiar terms can behave differently.
Do not ignore mandatory rules
Some rules apply despite the contract wording. Consumer protection is the clearest example. Employment, competition, data, financial services, and insurance rules may also limit what parties can agree.
A contract can choose a law, but it cannot always escape mandatory protection.
This matters in standard terms. A limitation clause may look strong. It may still fail if it breaches consumer law or is unreasonable. A non-compete may look clear. It may still fail if it goes beyond what the law allows.
Give special attention to these clauses
Cross-border contracts should treat the following clauses as high-risk:
Governing law Name the exact legal system.
Dispute forum State the court or arbitration process.
Liability limits Make caps, exclusions, and carve-outs clear.
Warranties Say which promises are given and which are excluded.
Termination State when a party can end the contract and what follows.
Notice Give clear methods and timing rules.
Payment and currency State the currency, taxes, bank charges, late payment, and interest.
Delivery and risk Say when risk passes and who bears transport loss.
Third party rights State whether non-parties can enforce terms.
Entire agreement State whether the written contract is the whole deal, while preserving claims that cannot be excluded.
Practical example of the same clause getting different treatment
Take a clause that says:
“The supplier’s total liability is limited to the amount paid under this contract.”
Under English law, this may face reasonableness controls in some business contracts and strong limits in consumer contracts. It must also use clear wording. It may not exclude liability for certain matters, such as death or personal injury caused by negligence.
Under US law, the result depends on the state, the contract type, and the facts. Commercial contracts often enforce clear limits. Consumer contracts may face stricter review. A court may refuse a clause if it is extremely unfair or hidden in a one-sided process.
The same sentence can survive in one case and fail in another. Context decides.
Practical example of informal promises
A landlord tells a tenant, “You can pay half rent for three months while repairs are ongoing.” The tenant relies on that statement.
Under English law, the tenant may argue promissory estoppel if the landlord later demands full rent for the same period. The doctrine may prevent the landlord from going back on the promise, at least for that period. It may not create a new claim for money on its own.
Under US law, depending on the state, reliance on the promise may support a stronger claim. The court may enforce the promise if refusal would cause injustice.
The words are the same. The legal route differs.
Practical example of standard terms
A buyer sends a purchase order with English law terms. The seller sends an acknowledgement with Texas law terms. Goods ship. The goods fail. Each side points to its own terms.
An English court may ask which form was last sent and accepted by conduct. A US court applying the relevant state version of the Uniform Commercial Code may find a contract despite the mismatch, then decide which terms became part of it.
The result may affect warranty, liability, and court choice. That is not a small point. It can decide the case.
The comparison in plain terms
US and English contract law are close enough to mislead people. The language is familiar. The concepts overlap. The differences still bite.
The strongest similarities are these:
Both systems come from common law.
Both enforce bargains, not vague hopes.
Both require agreement and value given in return.
Both prefer compensation over punishment.
Both respect written contracts.
Both limit unfair clauses in certain settings.
Both give greater protection to consumers.
The strongest differences are these:
English law is more unified for England and Wales.
US law varies by state.
US law often gives good faith a wider role.
English law places strong weight on the final written text.
US law can be more open to trade practice and outside evidence.
Consideration has more reliance-based exceptions in the United States.
Goods contracts follow different statutory frameworks.
Third party rights and unfair terms rules use different legal routes.
A good cross-border contract should not try to average the two systems. It should choose one governing law, one dispute forum, and clear wording built for that choice.
FAQ
Is English contract law the same as UK contract law?
No. English contract law usually means the law of England and Wales. Scotland and Northern Ireland have different legal systems. A contract should name the exact legal system.
Is there one single US contract law?
No. Contract law in the United States is mostly state law. A contract should name the state law that governs it, such as New York law or California law.
Which system is better for commercial contracts?
Neither is better in every case. English law is often valued for predictability and a strong focus on written terms. US law may offer more flexibility, but state variation matters. The best choice depends on the transaction, parties, assets, and enforcement plan.
Are verbal contracts valid in both systems?
Yes, many verbal contracts can be valid in both systems. Some contracts must be in writing or evidenced in writing, such as certain land contracts or guarantees. Written contracts are safer because they reduce proof problems.
Can a contract choose English law but use US courts?
Yes, in many cases. It can also choose a US state law and use English courts. This may add cost because the court may need evidence about the foreign law. The governing law clause and court clause should be planned together.
The takeaway
US and English contract law share the same foundation, but they do not produce the same result every time. The United States brings state-by-state variation and a wider role for good faith in many settings. English law brings a more unified system for England and Wales and a strong focus on the words the parties signed.
The safest approach is direct. Choose the exact law. Choose the exact forum. Write the key terms in plain words. Do not assume a familiar phrase carries the same effect on both sides of the Atlantic.
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