This book offers a detailed comparison between "culpa in contrahendo" and "promissory estoppel."

It examines the "culpa in contrahendo," a concept developed within Civil Law systems — especially in Germany, Italy, France, and Spain — together with "promissory estoppel," a figure from Common Law, paying particular attention to its operation in the U.S. legal system.

A key difference lies in the third type of "culpa in contrahendo," which requires proof of "bad faith" to claim damages — a condition absent in "promissory estoppel," which thus becomes a more effective and fairer instrument before the courts.

The second aspect of "culpa in contrahendo," related to consumer protection and the duty to inform buyers before concluding a contract, is comparable to "misrepresentation" in Common Law.

This topic was the subject of William R. Lizárraga Ugarte's doctoral research at the Universitat Autònoma de Barcelona, where he analyzed 1,000 Common Law cases and 500 Civil Law cases from Spain, Italy, Germany, and France.

Volume I: Core analysis and comparative framework.

Volume II: Civil Law cases (Germany, Italy, Spain, France) analyzed from the perspective of Promissory Estoppel.

Volume III: Promissory Estoppel cases (mainly from Common Law systems) analyzed from the standpoint of Culpa in Contrahendo.

Available at WorldCat

Available at WorldCat (Universidad de Valencia)

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