This article elucidates certain changes over the last decade in the way lawyers, judges and scholars addressed the question of codifying contracts and torts rules in European private law. I aim to demonstrate how the transatlantic trade in legal ideas helped alter the arguments made by lawyers engaged in the debate on European private law. Methodologically, this article departs from a timeworn comparative technique of emphasizing differences and similarities between rules and doctrines in United States and Europe. Rather, it focuses not only on the role played by legal doctrines, but also on the role of scholarly work, legal theories and ideologies in the reception and the production of legal thought on both sides of the Atlantic.