2. Pleading standards differ in other countries. Generally, courts abroad require a plaintiff to allege facts supporting her claim with reasonable particularity.

See Sherman, Transnational Perspectives Regarding the Federal Rules of Civil Procedure, 56 J. Legal Educ. 510, 515 (2006). The Principles of Transnational Civil Procedure, issued by the American Law Institute together with the International Institute for the Unification of Private Law, likewise require that pleadings “be in detail with particulars as to the basis of claim and that the particulars reveal a set of facts that, if proved, would entitle the claimant to a judgment.” Hazard, Taruffo, Sturner & Gidi, Introduction to the Principles and Rules of Transnational Civil Procedure,33 N.Y.U. J. Int’l L. & Pol. 769, 775 (2001). Is this standard similar to the detail required under the codes? Do you see any problems with this approach?

Any advantages? Of what relevance to the pleading standard is the fact that many countries abroad depend on professionally staffed administrative bureaucracies, rather than individual litigation, to resolve mass harms? See Chase, Hershkoff, Silberman, Taniguchi, Varano &

Zuckerman, Civil Litigation in Comparative Context 423 (Chase & Hershkoff eds., 2007). As you read the materials in this Chapter, consider the extent to which pleading standards in the United States are returning to code-like standards. See Dodson,Comparative Convergences in Pleading Standards, 158 U. Pa. L. Rev. 441 (2010). What are the implications of that change for a legal system built upon the principle of individual autonomy and adversarial justice? See Miller, From Conley to Twombly to Iqbal: A Double Play on the Federal Rules of Civil Procedure, 60 Duke L.J. 1, 71 (2010).