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Reynolds, 1996, p. 408 ff. [14] Bowstead and Reynolds (n. 13), p. 410. [15] See the Spanish cdigo de comercio, art. 287: �El contrato hecho por un factor en nombre proprio, le obligar directamente con la persona con quien lo hubiere celebrado; mas si la negociacin se hubiere hecho por cuenta del principal, la otra parte contratante podr� dirigir su accin contra el factor o contra el principal.�.� [16] Lupoi, Elementi di �civil law� nell� �agency�: la terminologia, Foro italiano, 1980, V, 137; id., �Agency�, in Enciclopedia giuridica, I, 1988.

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