ABSTRACT
The difficulty of finding a harmonised global solution to the protection of consumers in cyberspace lies not only in the inherent conflict between the need for consumer protection and the recognition of traders’ interests in accessing the global electronic marketplace, but also in the different choices that consumers coming from different cultures make when considering what level their protection should reach. This is indeed obvious in the emergent European legal culture. Muir Watt outlines that:
vast areas of what might be termed the ‘modern’ law of obligations, such as consumer protection (…) as well as an increasingly large part of private international law (…) are all affected by the move to harmonise and unify the individual legal systems. It is here that the whole issue of ‘Europeanisation’ becomes extremely sensitive, insofar as one may call into doubt the legitimacy of a deliberate filing down of those cultural differences which are characteristic of the various legal traditions represented within the European Union.1
