13th Nov 2015

​Where American and UK contracts clash

As IT lawyers with clients based in the USA and Australia, we are often working with turning overseas software licensing and SaaS contracts into documents which work in the UK. The challenges are interesting – American documents have great blocks of text rather than being broken down into bite-sized chunks; and there are US specific clauses which the hegemonic (good word) Americans are reluctant to relinquish even when they don’t apply.

For British contracts, though, it’s important that the documents include elements which are dealt with differently over the other side - anti-bribery provisions, data protection and jurisdictional clauses, for instance. There’s more to it than just changing the letter “z” to “s” throughout. We are two people divided by a common language!

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