Security Rights in Movable Property in European Private Law

Professor of German and European Private Law and Private International Law at Universität Würzburg, Germany.

• Part I. Introduction and context: 1. Introduction Eva-maria Kieninger; 2. A labyrinth of creditors Willem J. Zwalve; 3. Security in movables in the United States Harry C. Sigman; 4. The English law of security Michael Bridge; 5. The European Bank for Reconstruction and Development's Secured Transactions project Frederique Dahan and John Simpson; Part II. The Case Studies; Evaluation: a common core? Convergences, subsisting differences and possible ways for harmonisations Eva-maria Kieninger; Indexes.

'The volume is a profound comparative study which discusses the main problems of the European law of security rights in movable property in depth. … The study … is a valuable contribution to scholarship in the field of security law, but also to comparative property law in general. The neutral and descriptive approach of the study constitutes a good basis for further scholarly and political discussions on the harmonisation of security law. The case-orientated approach makes it also a good device for legal education. The volume thus can serve as a useful basis for a course or seminar on comparative property law. The picture that is drawn shows clearly that there is space and need for activity by the European Union.' Maastricht Journal of European and Comparative Law