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From the 1850s to the 1870s, English merchants campaigned for the introduction of commercial courts based on continental-European models. The courts were however not created. This paper discusses why the campaign was launched and why it failed. It points to the effect of a legal culture that does not correspond to the usual definitions of common law; the English culture was very different from that of the United States. It is still useful to use the phrase “legal culture” to describe interactions between four elements that hindered the transfer: the definition of important procedures by lawyers; the distant respect toward law displayed by merchants; their limited access to courts; and their self-categorizations (which involved more differences than similarities among merchants).