Abstract
Subsumed here, in both the English title and the French title, are common law and civil law concepts such as 'propertypatrimoine mobilier immobilier'; 'things' 'bien(s)'; 'ownership' 'propriete.' It is essential to have an understanding of these concepts, and sometimes faux amis, to seize as well as possible the comparative perspective of the questionnaire. In Black's Law Dictionary we find the following definition of: Property: 1. The right to possess, use, and enjoy a determinable thing (either a tract of land or a chattel); the right of ownership (the institution of private property is protected from undue governmental interference) . . .' It is important to mention here that, in the Ameri can legal system, property rights and interests are created and de fined by state law so that the federal government of the United States does not have the authority to define what property rights and inter ests are. Those rights and interests are the creature of state law. In the same Black's Law Dictionary we find the following definition of:
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