The financial crisis and ensuing losses suffered by counterparties to various structured product transactions has provoked an outbreak of "misselling" cases. A number of cases have been heard by the English courts but proceedings have also been brought in jurisdictions across Europe, including Germany. In this article, Arun Srivastava and Mathias Wittinghofer, partners at Baker & McKenzie LLP, consider the outcome of cases in Germany and England and the lessons that can be learnt from the differing trends in these jurisdictions.