IV. Conclusion
558
National laws provide claims that protect the property in the goods. Yet, there are major differences. While some legal systems protect owners by allowing them to (re-)gain possession of the goods, other legal systems protect owners through respective damages claims. As far as a third party raises any of such claims against a party to a CISG contract, the CISG does not preempt the claim. As far as a party to a CISG contract relies on such claims against a third party, the CISG also does not preempt the claim. When either the buyer or the seller to a CISG contract relies on such claims against the contractual partner, the central question is whether the CISG would also