개정 미국통일상법전(UCC) 제2편(물품매매)의 비교법적 고찰 - 서식전쟁(Battle of Forms) 부분을 중심으로 -
A Comparative Study on Revised Uniform Commercial Code, Article 2 (Sale of Goods) - Focusing on the Battle of Forms in Contract Formation -
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The American Law Institute and the National Conference of Commission on Uniform State Laws amended Article 2 of the Uniform Commercial Code in 2003. One of the most urgent and challenging tasks the sponsoring organizations undertook in amending the Sales Article of the Code was to revise UCC section 2-207, the “battle of the forms” section that will live in infamy. In revising the original statute (hereinafter referred to as UCC-O section X-XXX), the drafters decided to move the rule stated in UCC-O section 2-207(1) to revised section 2-206(3) (hereinafter referred to as UCC-R section X-XXX), so that all of the standards governing formation of a contract for sale by acceptance of an offer are now collected in UCC-R section 2-206. In the proposed amendment of Article 2, a revised section 2-207 replaces subsections (2) and (3) of UCC-O section 2-207. The sole province of UCC-R section 2-207 is to identify the terms of a contract for the sale of goods. The language of UCC-R sections 2-206(3) and 2-207 and the proposed Official Comments to those sections improves upon the language of UCC-O section 2-207and its Official Comments. Adoption of the revised statute will make much of the case law and scholarly commentary interpreting the original statute obsolete. Despite the improvement, however, the language of UCC-R sections 2-206(3) and 2-207 still does not provide sufficiently clear and thorough guidelines for resolving the questions of sales contract formation and content that those sections address. This article provides a overview of the relevant original statutes in a critical manner and then provides an evaluation of revised UCC sections 2-206(3) and 2-207. Part of the evaluation identifies the many ways in which language of the revised statutes improves upon the language of their predecessor. The evaluation also suggests how the text of UCC-R sections 2-206(3) and 2-207 might be further revised or interpreted in order to provide needed guidance when the revised statute are adopted. In addition, this article provides a short comment of the equivalent sections in both UN Convention on the Contract for International Sale of Goods (CISG) and UNIDROIT Principles on International Commercial Contract (PICC) as to the changed acceptance
Abstract
The American Law Institute and the National Conference of Commission on Uniform State Laws amended Article 2 of the Uniform Commercial Code in 2003. One of the most urgent and challenging tasks the sponsoring organizations undertook in amending the Sales Article of the Code was to revise UCC section 2-207, the “battle of the forms” section that will live in infamy. In revising the original statute (hereinafter referred to as UCC-O section X-XXX), the drafters decided to move the rule stated in UCC-O section 2-207(1) to revised section 2-206(3) (hereinafter referred to as UCC-R section X-XXX), so that all of the standards governing formation of a contract for sale by acceptance of an offer are now collected in UCC-R section 2-206. In the proposed amendment of Article 2, a revised section 2-207 replaces subsections (2) and (3) of UCC-O section 2-207. The sole province of UCC-R section 2-207 is to identify the terms of a contract for the sale of goods. The language of UCC-R sections 2-206(3) and 2-207 and the proposed Official Comments to those sections improves upon the language of UCC-O section 2-207and its Official Comments. Adoption of the revised statute will make much of the case law and scholarly commentary interpreting the original statute obsolete. Despite the improvement, however, the language of UCC-R sections 2-206(3) and 2-207 still does not provide sufficiently clear and thorough guidelines for resolving the questions of sales contract formation and content that those sections address. This article provides a overview of the relevant original statutes in a critical manner and then provides an evaluation of revised UCC sections 2-206(3) and 2-207. Part of the evaluation identifies the many ways in which language of the revised statutes improves upon the language of their predecessor. The evaluation also suggests how the text of UCC-R sections 2-206(3) and 2-207 might be further revised or interpreted in order to provide needed guidance when the revised statute are adopted. In addition, this article provides a short comment of the equivalent sections in both UN Convention on the Contract for International Sale of Goods (CISG) and UNIDROIT Principles on International Commercial Contract (PICC) as to the changed acceptance
참고문헌 (16)
- 김선국, "미국통일상법전 제 2편(매매)의 주요 개정논점", 경영법률, 17(1), pp.69~96 (2006), 한국경영법률학회
- 김선국, "비교 계약법적 관점에서 본 CISG: 앞으로의 과제 -Battle of Forms와 몇 가지 점을 중심으로-", 국제거래법연구, 18(1), pp.29~47 (2009), 국제거래법학회
- 최흥섭, "유엔국제매매법(CISG)에서 약관에 관한 문제", 법조, 55(1), pp.104~139 (2006), 법조협회
- "현행 Uniform Commercial Code, Article 2-207", ~
- "Restatement of Contract Second", ~
- "개정 Uniform Commercial Code Article 2 (2003)", ~ (2003)
- "UN Convention on Contract for International Sale of Goods", ~ (1980)
- "UNIDROIT Principles of International Commercial Contract", ~ (2004)
- Henry D. Gabriel, "The Battle of the Forms: A Comparison of the United National Convention for the International Sale of Goods and the Uniform Commercial Code", Business Lawyer, 49(1053) (1994)
- Clayton P. Gillette, "Sales Law - Domestic and International" (2009), Foundation Press
- John Honnold, "Uniform Law for International Sales under the 1980 United Nations Convention" (2009), Wolters Kluwer
- Charles M. Thatcher, "The Long Awaited Official Overhaul of U.C.C. Section 2-207: An Essay on the Limits of Improvement", 51 South Dakota Law Review, pp.296~ (2006)
- John L. Utz, "More on the Battle of the Forms: The Treatment of “Different” Terms under the Uniform Commercial Code", Uniform Commercial Code Law Journal, 16(103) (1983)
- "General Electric Co. v. G. Siempenkamp GmbH & Co., 29 F.3d 1095, 1099(6th Cir. 1994)", ~ (1994)
- "Northrup Corp. v. Litronic Industries, 29 F.3d 1173, 1178 (7th Cir. 1994)", ~ (1994)
- "Weyburn-Bartel, Inc. v. Zagar, Inc. 1996 Lexis 16988 (W.D. Mich. 1996)", ~ (1996)
