Société par actions simplifiée (SAS, English: "simplified joint-stock company") is the first hybrid law enacted under French law and based on common law principles rather than civil. It is similar to a limited liability company under United States law, as the Delaware limited liability company was the model used by the French Government. The SAS is also similar to the  limited company in the British law, and most other hybrids; though the hybrid in civil law countries is quite different because there is also a hybrid of common law principles applied.