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Long before the current crisis triggered by the recent United States initiatives in trade and monetary policy,' a crisis of quieter dimensions was taking shape in GATT legal affairs.2 For some years now, the GATT's code of detailed substantive obligations has been in failing health. One source of the difficulty has simply been old age, for a number of the rules written in 1947 have become unresponsive to current attitudes and market conditions. A more basic problem, however, has been an increasing tendency among GATT participants to question the utility of any detailed substantive rules. Many have argued that the GATT would operate more effectively if it turned away from rule-oriented regulation and tried instead to influence govern-

GATT or GABB? The Future Design of the General Agreement on Tariffs and Trade