 For the critics, however, the problem seems deeper. Some structural features of private law may not vary across jurisdictions but the rules and the reasons for them do. It is less clear how one explains a mass of reasons and rules from different jurisdictions. The difficulty increases the more diverse the set of jurisdictions is. We might expect tort law in the United States to be relatively uniform across the fifty states. After all, the states largely share an approach to opinion writing and judges of one state may refer to the decisions of another. We would expect courts from different states to offer similar  types of reasons. That unity might decrease if we consider all common law jurisdictions. After all, the conventions of opinion writing vary across these jurisdictions. Opinions issued from the judges of the Queen’s Bench do not obviously offer similar types of reasons as those issued by the California Supreme Court. An expansion to civil law jurisdictions increases the range of styles. Opinions of the French Cour de Cassation look nothing like the opinions of the two previously mentioned common law courts.