Given this mixed bag of comparative experience, I remain reluctant to declare allegiance to either the common-core or the difference-dominant school, though I do think my research output during the past decade or so reflects increasing sympathy for the postmodern position.

To illustrate my experience in this regard, both as a student and later as professor of law, I will now examine some issues that fall within the following categories: (1) the contracting process (aftaleindgåelsen), ⁹³²932. See Farnsworth, surpa n. 4, Ch. 3; Andersen, supra n. 5, Ch. 3. (2) defenses to contract enforcement (ugyldighed), ⁹³³933. See Farnsworth, id., Ch. 4 (Policing the Agreement); Andersen, id., Ch. 6. and (3) remedies for breach (misligholdelsesbeføjelser). ⁹³⁴934. See Farnsworth, id., Ch. 8 (Performance and Nonperformance); Mads Bryde Andersen & Joseph Lookofsky, Lærebog i obligationsret (Vol. I, 4^th ed. 2015) Ch. 5.

More specifically, I will explain and compare how American and Danish domestic contract law deal with the issues of (1) revocability, (2) unconscionability and (3) impracticability. I will also consider these issues as they relate to the harmonized part of American and Danish commercial contract law: the CISG Convention.

In each instance: Is there a common domestic core, and does it shine through in the CISG? If not, does the homogenized CISG version conceal domestic differences that could not be legislated away?

As a first-year law student in Copenhagen in 1975, I remember reading (and re-reading) the starkly formulated proposition, codified in §1 of the Danish Contracts Act (1917), that ‘promises ... are legally binding.’ ⁹³⁵935. § 1 of the Danish Contracts Act (Aftaleloven), available in English at https://www.trans-lex.org/604900/_/danish-contracts-act/, as then presented in my Copenhagen textbook: Munch-Petersen, Den borgerlige ret (21st ed. 1973) at 191 (løfter og kontrakter er retlig bindende). See also supra n. 5. Period! Put another way, once the promisor (promise-maker) communicates his promise to the promisee (recipient), the promisor is bound, ⁹³⁶936. For the time stated in the offer or for a reasonable period of time. irrespective of whether or not that promisor has received anything in return.