Die Rügefrist des Art. 39 CISG

The CISG (also known as the "Vienna Sales Convention") is now in effect in almost one hundred contracting states. However, there is no supranational appellate body that could ensure uniform application of the law. Thus, interpretation and application are solely the responsibility of national courts. It is evident that this can lead to divergences. The most common point of contention in the application of the CISG is the notice of defects regulated in Article 39 of the CISG. This dissertation from Freiburg undertakes a systematic analysis of the case law of selected contracting states (Australia, Germany, France, Canada, Austria, Switzerland, and the USA), revealing both commonalities and contrasts. These contrasts can sometimes (but not consistently) be explained by the national regulations of the sales contract.