Of particular concern is the reference in this article to “Good Faith.” While no one is advocating that contracts be conducted in “bad faith”, it is quite another thing to be advocating “Good Faith.” There are a variety of reasons for this controversy, no single one of which adequately explains the problem. First, it is a manifestly different concept in the common law and civil law jurisdictions that make up the majority of the world’s legal systems. While traditionally, common law systems have rejected it, in the civil law systems, it is a broad, general and far reaching concept