Civil law and common law are often viewed as given way to largely different proprietary models. On the one hand, absolute property, analyzed as a material-object real right; on the other, an essentially divisible and relative property, a bundle of rights susceptible of bearing on a material or immaterial object. This article seeks to question the radical opposition between the Property laws of civil and common law. The thesis advanced here is that it is possible to bring closer the concept of property in civil and common law, through the idea of a relational and incorporeal property, which could be a starting point for a transsystemic definition of property.