only after the publication of a conimentar\'. The Armenian commentar\' will he based on the Russian! How can this he? Are Russia and Armenia the same place? Haxe they become the same culture? Or can it be that law can he transplanted?'’ VI. Finally for this part of the chapter I would like to look at one other different type of legal transplant, international sale of goods. It was long felt that transnational mercantile transactions would he greatU’ helped if there was a uniform contract law that crossetl national horders. I'hus came into force in 1988 the United Nations C'onyention on (contracts for the International Sale of Cioods. d'he contract of sale was chosen because it is the most important commmercial contract. Fhe Convention when it came into force did not represent the law' of any nation state. But since 1988 it has been enacted as law in •74 countries: an enormtvus e.vample of a legal transplant. Of course, it may he argued that the needs of transnational business make this a special case. Of course 1 agree. But that does not alter the fact that 'foreign' law could he accepted in many countries. Naturally enough, it was noticed that judicial interpretation in different countries could result in different results. (1 \yould point out though, that even h\' accepting the Convention the >4 countries bring their national law on the subject much closer together.) A first step in harmonizing the law is to hold that domestic proceedings do not transformthis C'onvention (and others) into domestic law, hence the domestic interpretative techniques are not applicable. This approach has been widelv’ successful, but as yet with notable e.xceptions. ' 'Fhe interpretation of the C>onv ention is not uniform within the >4 countries but there is a wide measure of agreement. 22 See already, Alan Watson, Ancient Law and Modern Understanding (Athens, Ga., 1998), pp. 84ff. 23 For a splendid modern treatment of the success in transplanting the Convention, and of the remaining difficulties see Franco Ferrari, International Sale of Goods (Basle, etc., 1999). (French version, Contrat de Vente Internationale). 112
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