Conflicts

Question 1

Choice of law analysis

Answer 1

Most significant relationship based on:

(a) needs of the interstate international system “we should use a system that respects the laws of other states and the restatement does so”
(b) relevant policies of the forum (protecting plaint./def.)
(c) relevant policies of other interested states
(d) protection of justified expectations (should use law where parties expected)
(e) policies of the area of law (contracts should enforce promises, such as choice of law, within the K)
(f) Certainty, predictability, uniformity of result