The law of the place where the contract was made. Lex Domicilii: The law of the person's permanent home.

Even if a court in New York agrees to hear a case, it doesn’t necessarily mean they will use New York law. If two French citizens sign a contract in Paris and later sue each other in New York, the judge may be required to apply French law to the dispute. To decide this, courts use "connecting factors":

The first hurdle in any cross-border dispute is determining which court has the authority to hear the case. This is not always simple. A plaintiff might want to sue in their home country for convenience, while the defendant prefers their own.

The (or Private International Law ) is the branch of law that handles legal disputes involving "foreign" elements. In an increasingly globalized world, where people live in one country, work in another, and sign contracts with companies in a third, this field acts as the "traffic controller" of international litigation.

Modern approaches have shifted toward the doctrine, which seeks the legal system with the most "significant relationship" to the transaction and the parties. 3. Recognition and Enforcement: Is the win valid elsewhere?