Abstract
The authors present the EU intentions to take legislative action in respect of class actions and outline the recent, national initiatives on class actions within the member States of the EU. Then, the main features of US class actions are outlined followed by a detailed examination of the new Danish provisions on class actions. The authors compare the US and the Danish provisions and conclude that the Danish provisions on class actions may serve as a model for future EU legislation given the Danish compromise between the opt-in and the opt-out model for class actions.
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