What are the differences between offer according to Civil Code of PRC, Common Law, Civil Law, and CISG. Please give an example explaining each difference

The differences between offer according to Civil Code of PRC, Common Law, Civil Law, and CISG are as follows:

1. Civil Code of PRC: In the People's Republic of China, an offer is an intention to enter into a contract upon acceptance by the offeree. The offer must be specific, definite, and capable of being accepted. For example, if A offers to sell his car to B for a specific price, this is considered a valid offer under the Civil Code of PRC.

2. Common Law: Under Common Law, an offer is a clear, unequivocal, and direct approach to another party to contract. It must be communicated to the offeree and it must contain definite terms. For example, if A sends a letter to B offering to sell his house for a certain price, this is considered a valid offer under Common Law.

3. Civil Law: In Civil Law systems, an offer is a proposal for concluding a contract, addressed to one or more specific persons, that is sufficiently definite and indicates the intention of the offeror to be bound in case of acceptance. For example, if A sends an email to B offering to provide consulting services for a certain fee, this is considered a valid offer under Civil Law.

4. CISG (United Nations Convention on Contracts for the International Sale of Goods): Under the CISG, an offer is a proposal for concluding a contract addressed to one or more specific persons that is sufficiently definite and indicates the intention of the offeror to be bound in case of acceptance. An offer must be communicated to the offeree. For example, if A sends a fax to B offering to sell 100 units of a product for a certain price, this is considered a valid offer under the CISG.

In summary, while the basic concept of an offer is similar across these legal systems, the specifics can vary, particularly in terms of how the offer is communicated and what it must contain.