Certify / Attest / Beglaubigen

I’ve been writing a lot in German about the use of the word ‘beglaubigen’ (certify) for translations, and forgetting to discuss how to translate some of these terms into English, as Adrian reminds me in a comment.

There is a Beurkundungsgesetz in Germany. It is all about notaries. I have translated it, sometimes, as Notarial Recording Act. Neither Dietl nor Romain has it, nor von Beseler – Jacobs-Wüstefeld. It is often translated as ‘Documents Act’, which I don’t much like.

German notaries either beurkunden or beglaubigen. If they beglaubigen (öffentliche Beglaubigung), they certify / witness a signature. Or attest. If they beurkunden (öffentliche Beurkundung), or record (the best word I’ve found, but not very transparent, unfortunately), they produce a whole document.

So I normally say:

|Beurkundungsgesetz|Notarial Recording Act|
|öffentliche Beglaubigung|notarial certification|
|öffentliche Beurkundung|notarial recording|

I don’t like to use notarization. Reasons: firstly, the term is associated in the US with a notary public’s witnessing of a signature, and so conjures up the idea of a different kind of notary. In addition, it is not clear whether beglaubigen or beurkunden is meant. – Of course, the word notarization works perfectly well in context, if one is careful – I’m just setting out my own objections. Continue reading

Certify / Attest / Beglaubigen

I’ve been writing a lot in German about the use of the word ‘beglaubigen’ (certify) for translations, and forgetting to discuss how to translate some of these terms into English, as Adrian reminds me in a comment.

There is a Beurkundungsgesetz in Germany. It is all about notaries. I have translated it, sometimes, as Notarial Recording Act. Neither Dietl nor Romain has it, nor von Beseler – Jacobs-Wüstefeld. It is often translated as ‘Documents Act’, which I don’t much like.

German notaries either beurkunden or beglaubigen. If they beglaubigen (öffentliche Beglaubigung), they certify / witness a signature. Or attest. If they beurkunden (öffentliche Beurkundung), or record (the best word I’ve found, but not very transparent, unfortunately), they produce a whole document.

So I normally say:

|Beurkundungsgesetz|Notarial Recording Act|
|öffentliche Beglaubigung|notarial certification|
|öffentliche Beurkundung|notarial recording|

I don’t like to use notarization. Reasons: firstly, the term is associated in the US with a notary public’s witnessing of a signature, and so conjures up the idea of a different kind of notary. In addition, it is not clear whether beglaubigen or beurkunden is meant. – Of course, the word notarization works perfectly well in context, if one is careful – I’m just setting out my own objections. Continue reading

Miss Marple of Botswana

The Independent reports that a Scottish law professor, Alexander McCall Smith, has had unexpected success in the USA with his book The No. 1 Ladies’ Detective Agency. His female detective, Precious Ramotswe, has been called ‘the Miss Marple of Botswana’ by the New York Times. The book was published in an edition of 2,00 in 1998 and there are four sequels. Donald Rumsfeld and his wife are fans (hmm…). Continue reading

Posted in law

Google U.S. vs. Google Germany

There has been some discussion on a German weblog about Google recently.
(Der Schockwellenreiter, actually quoting KerLeone:
– plus a large number of comments)
The general point is if you’re in Germany, Google presents you with German sites or at least a German page. Even if you click through to ‘Google.com in English’, the page has on it an invitation to go to Google Germany, which means they know you’re German, and you’re seeing a page intended for Germans only. Continue reading