Aus dem Papierkorbvon , veröffentlicht am 21.11.2018
A colorable approximation (stichhaltige Annäherung) exists whenever one can reasonably and justifiably make a determination that, without any claim to statutory or legal equivalence, different legal systems know significantly similar terms of art. And terms of art from different legal systems are significantly similar when their accepted definitions exhibit commonalities enough to justify an approximation on definitional grounds or when they denote something that exhibit commonalities enough to justify an approximation on structural grounds. More generally, terms of art from different legal systems are significantly similar when relevant commonalities exist on the grounds of which an approximation is justified that aids, and does not hinder, understanding. … This can’t be new.