additional arguments. For instance, the whole idea of a European codification is arrogant in his view, because it imposes on common lawyers the supposedly superior world view of continental lawyers. They each offer different accounts of reality and those preaching codification of private law consider the Anglo-American reality as without merit. A ECC is only in the interests of the European economy and consequently cultural differences must disappear. Furthermore, the suggestion that Europe with a ECC will return to a Golden Age of a true ius commune is misleading, because English law was never part of it. What to say about this line of arguing? Legrand's argumentation can be assessed as correct in essence. There is indeed a difference between English legal style with its eye for detail and the continental style with its emphasis on abstraction. Legrand's observation that this is evidenced, for instance, by the way decisions are studied in the two mentalities is intriguing. Paraphrased and translated for the Dutch situation this means that for a Dutch person the facts and circumstances in Lindenbaum v. Cohen or in Blaauboer v. Berlips(two seminal cases of Dutch private law)are far less interesting than the Netherlands Supreme Court's decision in these cases. Those teaching at Dutch Universities(and the same is true for Germany, France or Italy)want their students to know the rule the case itself comes second Not so in england and the United States, where the legal rule cannot be separated from the facts. Beware the student who does not know the facts and circumstances of the case and is not able to compare it with other cases On the basis of the above, Legrand rightly estimates that the chance of a successful ECC is very slight. As indicated earlier, a positivist world view does not fit ith the times: how could uniform law spring from a single uniform text, where a common (legal) culture-the determining factor in the courts' construing and pplementing uniform provisions-does not exist in Europe? The requirement that the ECC must be interpt law, as is also customary in the case of treaties, is not very eted according to its underlying principles rather than in onformity with national enlightning to legal practice Nevertheless, in my point of view Legrand s argumentation has a weak point. A more careful analysis reveals that he is not, in fact, against a European private law, but rather against a European Code imposed authoritatively, in which national cultural differences are terrorized away in a centralist fashion. The better part of his argumentation is aimed at this point. Legrand s objections are thus to the point if a European private law were to be achieved in a centralist way, but not where other methods are concerned. Another method of establishing a ius commune, for instance through academic scholarship or European education, he feels, is illusory in view of the still present national legal positivism. The third road, that of a European private law other than by centralism, is not really discussed by Legrand, apart from saying that Legrand 1997, at 56 ff. Cf Legrand 1997. at 49-50 Although he also expressly denies the desirability (Legrand 1996, at 62). This does not seem to quare with his own observations(Legrand 1997, at 62) where he questions understanding ithout terrorizing Civil Law and Common Law Legrand, 1996, at 53 Error! bookmark not definedError! Bookmark not defined. additional arguments.24 For instance, the whole idea of a European codification is arrogant in his view, because it imposes on common lawyers the supposedly superior world view of continental lawyers. They each offer different accounts of reality and those preaching codification of private law consider the Anglo-American reality as without merit. A ECC is only in the interests of the European economy and consequently cultural differences must disappear. Furthermore, the suggestion that Europe with a ECC will return to a Golden Age of a true ius commune is misleading, because English law was never part of it. What to say about this line of arguing? Legrand's argumentation can be assessed as correct in essence. There is indeed a difference between English legal style with its eye for detail and the continental style with its emphasis on abstraction. Legrand's observation that this is evidenced, for instance, by the way decisions are studied in the two mentalités is intriguing. Paraphrased and translated for the Dutch situation this means that for a Dutch person the facts and circumstances in Lindenbaum v. Cohen or in Blaauboer v. Berlips (two seminal cases of Dutch private law) are far less interesting than the Netherlands Supreme Court's decision in these cases. Those teaching at Dutch Universities (and the same is true for Germany, France or Italy) want their students to know the rule; the case itself comes second. Not so in England and the United States, where the legal rule cannot be separated from the facts. Beware the student who does not know the facts and circumstances of the case and is not able to compare it with other cases.25 On the basis of the above, Legrand rightly estimates that the chance of a successful ECC is very slight. As indicated earlier, a positivist world view does not fit with the times: how could uniform law spring from a single uniform text, where a common (legal) culture - the determining factor in the courts' construing and supplementing uniform provisions - does not exist in Europe? The requirement that the ECC must be interpreted according to its underlying principles rather than in conformity with national law, as is also customary in the case of treaties, is not very enlightning to legal practice. Nevertheless, in my point of view Legrand's argumentation has a weak point. A more careful analysis reveals that he is not, in fact, against a European private law, but rather against a European Code imposed authoritatively, in which national cultural differences are `terrorized away' in a centralist fashion. The better part of his argumentation is aimed at this point.26 Legrand's objections are thus to the point if a European private law were to be achieved in a centralist way, but not where other methods are concerned. Another method of establishing a ius commune, for instance through academic scholarship or European education, he feels, is illusory in view of the still present national legal positivism.27 The third road, that of a European private law other than by centralism, is not really discussed by Legrand, apart from saying that 24 Legrand 1997, at 56 ff. 25 Cf. Legrand 1997, at 49-50. 26 Although he also expressly denies the desirability (Legrand 1996, at 62). This does not seem to square with his own observations (Legrand 1997, at 62) where he questions understanding without `terrorizing' Civil Law and Common Law. 27 Legrand, 1996, at 53