court to a European appellate instance or from a European court of first instance to a national supreme court, depending on the issues that need to be decided. It may give rise to a lot of forum shopping, but exactly this may lead petition between the two jurisdictions, furthering their effectiveness. For a national judge, it might be a promotion to be appointed as a member of a European court. And a judge in a European court might be promoted to a higher national court.Р?Before I e too technical, I should end this paper. My last observation is that a well-functioning European contract law is only possible if we eed in finding workable solutions for those technical aspects of procedural law. What is at stake here is access to justice. Without it, there is no point in unifying European law.