The Conflict Of Laws 【99% SIMPLE】

The law of the place where the wrong (tort) was committed.

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 Conflict of Laws

The law of the place where the contract was made. Lex Domicilii: The law of the person's permanent home. The law of the place where the wrong (tort) was committed

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": A plaintiff might want to sue in their