[johndhi]

Exactly. Yes. That's the idea.

The US legal system relies more on "ex post" legal enforcement - meaning, if you break the law then you get busted and you personally pay the victim. Europe is a more "ex ante" system - they rely on regulators to strictly define what the law should look like exactly and actually requires industry to do very specific things to comply with it. If someone gets hurt the system compensates them from a fund. The person who hurt them doesn't necessarily pay.

That's the theoretical underpinning and difference in our systems. But like I said the systems have a bit of both these days. Eu is flirting with more class actions, and US has more regulatory scrutiny in certain sectors, like California privacy laws for example being very detailed.

[eru]

UK doesn't seem to have quite as much suing as the US? And they also have a common law system.

In contrast, German military procurement is famous for its endless lawsuits.

[johndhi]

One different with UK is they use the 'English Rule' of fee-shifting. In English civil lawsuits, the losing party has to pay the attorneys fees of the other party.

In the US, there's basically no downside of suing someone if you can keep your own costs down.

[eru]

That makes sense, thanks!