The law of the place where the contract was made. Lex Domicilii: The law of the person's permanent home.
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 wrong (tort) was committed. The law of the place where the contract was made
It fundamentally addresses three questions: , Choice of Law , and Recognition of Judgments . 1. Jurisdiction: Where should the case be heard? Choice of Law