Winship, Peter, The Convention on the Limitation Period in the International Sale of Goods: The United States Adopts UNCITRAL's Firstborn, 28 Int'l Lawy. 1994, at 1071 et seq.

940000The Limitation Convention's preamble asserts that "the adoption of uniform rules governing the limitation period in the international sale of goods would facilitate the development of world trade." Implicit in this assertion is the judgment that the nonuniformity of existing national laws creates legal barriers to the free flow of transnational trade. This judgment was quickly reached by the U.N. Commission, which took up the subject "immediately" because studies "revealed numerous disparities between the rules of law of domestic legal systems 

940000and a fundamental difference of approach in the civil law and common law systems."22

[Subsequently set out in detail.]

22Report of the United Nations Commission an International Trade Law an the work of its second session, U.N. GAOR, 24th Sess., Supp. No. 18, U.N. Doc. A/7618 (1969), reprinted in [1968-1970] 1 Y.B. UNCITRAL 94, 100 (para. 44), U.N. Doc. A/CN.9/SER.A/1970.

22Report of the United Nations Commission an International Trade Law an the work of its second session, U.N. GAOR, 24th Sess., Supp. No. 18, U.N. Doc. A/7618 (1969), reprinted in [1968-1970] 1 Y.B. UNCITRAL 94, 100 (para. 44), U.N. Doc. A/CN.9/SER.A/1970.