Schädigermehrheit im europäischen internationalen Deliktsrecht

The Rome II regulation contains no coherent concept for multiple tortfeasors in private international tort law. This regards a deviation in the applicable law for the damaged party and one of several tortfeasors for objective or subjective reasons, imputation if there are several places where the damage or the event giving rise to it occurred, and questions of compensation. To develop a coherent interpretation of the regulation, this work systematically examines relevant groups of cases under the regulation, criteria for imputation in EU law (p.e. rules of international civil procedure, traffic accidents, product liability and cartel damages, public environ-mental and criminal law) and models drawn from comparison of legal systems.