Arbitration has deep roots in the legal cultures of the United States and Germany--and is still an important option for resolving disputes in both countries today. As far back as Colonial times, US merchants used arbitration to settle industry disputes, and in the early 19th century, American stockbrokers resolved intra-industry disputes through arbitration at the New York Stock Exchange. In Germany, a country with a civil law rather than a common law tradition, commercial arbitration has been practiced for centuries: the first draft of the German Code of Civil Procedure from 1877 included a section establishing the legal foundations of arbitration.
Christian Duve & Jill I. Gross, Commercial Arbitration: Germany and the United States, 24 Disp. Resol. Mag. 15 (2017), https://digitalcommons.pace.edu/lawfaculty/1174/.
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