CISG상의 연착된 승낙과 청약의 취소통지 연착에 관한 연구 - 우리나라 민법에의 적용 가능성과의 연계연구

Research on Late Acceptance and Late Revocation Notice of Offer in CISG - Connected Study with an Application Possibility on the Korean Civil Law-

  These days, late acceptance and late revocation notice of offer has become prominent in the consideration of which laws should be applied or interpreted as the governing law for parties in case of disputes in international trade. Through a comparison of CISG, Korean civil law, and Japanese civil law, this study has examined the "late acceptance" and "late revocation notice of offer" which has frequently brought bottlenecks due to no justified regulation on the CISG, even if the offerer and offeree have been influenced by each other. Also it compared the relationship between general principles of late revocation notice of offer in the CISG, Korean civil law and Japanese civil law. The aim of this research lies in focusing on some parts of Korean civil law which need to be revised based on these comparisons. To achieve the purpose of this study, related literatures have been compared, reviewed and analyzed.