Comparative law notes
Although the concept of "joint and several liability" is well-known in the common law world, this particular phrase is not ordinarily used in the US or UK. It is used, however, in certain international contexts such as the Unidroit Principles 2010 for Commercial Contracts (ARTICLE 11.1.2 (PRESUMPTION OF JOINT AND SEVERAL OBLIGATIONS), which is the exact conceptual match to the German concept of Gesamtschuldner.