1. (questioning the usefulness of a general notion of juridical act in the;Common Frame of Reference
2. explaining that several European jurisdictions are unfamiliar with the German concept of Rechtsgesch�ft). 196. For a detailed discussion of the historical foundations of the Louisiana civil law system, see;Nils Jansen;Contract Formation and Mistake in European Contract Law: A Genetic Comparison of Transactional Model Rules,2011