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目前关于证券民事案件诉讼方式的研究较多,对于美国证券集团诉讼机制对于我国的借鉴意义也有不少讨论,但对于中美证券民事案件诉讼方式进行全面的比较研究却相对较少。文章从诉讼前置程序、受案范围、诉讼的发动、结案方式及判决效力等方面对中美证券民事案件诉讼方式进行全面的比较,以期我国相应体制的建立与健全。
At present, there are many researches on litigation methods in securities and civil cases. There are also many discussions about litigation mechanisms of securities companies in the United States for reference. However, there are relatively few comparative studies on the litigation methods of securities cases in China and the United States. The article makes a comprehensive comparison of the litigation methods of civil cases in China and the United States in terms of the pre-litigation procedures, the scope of the cases, the launching of litigation, the methods of settlement and the effectiveness of judgments, so as to establish and improve the corresponding system in our country.