Clearly different standards regarding the regulation

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There are basically three kinds of legal systems in countries throughout the world: civil law legal systems, common law legal systems, and theocratic law legal systems. A civil law legal systemis a legal system based on a comprehensive listing of legal rules in sets of written codes of law. For example, a code in a civil law country could specifically list the different types of pornography that were permissible in the given society along with which types of pornography were impermissible or illegal.In a civil law country, the real power lies with the legislative branch of government, which enacts specific laws or rules that are then set forth in given legal codes. Judges in civil law countries have relatively little power, as the codes set forth specific rules and the job of the judges is simply to enforce these specific rules. There is little room incivil law countries for judicial “interpretation” or changing of legal regulations—the rules are specifically and comprehensively set forth in given codes, and only the legislative branch of government can change these rules by passing new laws that alter the given codes.From a cultural perspective, civil law systems provide considerable uncertainty avoidance. Citizens clearly know the given rules and judges straightforwardly enforce these codified rules. It is thus not at all surprising that countries likeGermany, with strong cultural preferences for uncertainty avoidance, are civil law countries. Indeed, Germany’s Civil Code of 1896 and its general civil law system have diffused not only into most other European countries (e.g., Switzerland and Austria), but also into Asia. Indeed, Japan, heavily influenced by Germany’s 1896 civil code, adopteda similar civil code later that same year. In turn, Japan’s civil legal system has been adopted in good measure by other Asian countries, such as China, South Korea, and Taiwan. Companies and individuals planning on doing business in civil law legal system countries need to carefully review existing rules and codes that apply to the nature of business they are going to be conducting. Over 80 countries in the world are currently civil law legal system countries.Common law legal systems, such as the supreme court of the United Kingdom, allow for legal interpretation by judges and courts.
In contrast to countries with a civil law legal system, the United States follows a common law legal system. A common law legal systemis one where legislative bodies generally enact less specific legal rules, so that judges and courts are given considerable authority with respect to interpreting these rules based on precedent and other factors. For example, a common law legal system might simply afford its citizens the right to be free from government interference with their “free speech.” It would then be up to judges to interpret the term “free speech”based on precedent and other evidence and considerations (e.g., does a given piece of pornographic material represent permissible “free speech”?).

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