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Property in goods is a field of law that has not been subject to unification, and national laws differ widely. There are different notions of property. In some legal systems, property is an absolute notion, while in other legal systems, property refers to a relative notion. Under such a notion, multiple persons can have property in the same goods. Other legal systems try to avoid relying on property as an abstract concept, and rather aim at finding solutions to the respective question at hand. Moreover, the transfer of property differs under national laws. Generally, the lex rei sitae is applied to decide which notion of property and which kind of mechanism for the transfer of property applies.