Quote:
Originally Posted by onetwo_threefour
Choice of law isn't always that simple though. If they executed and made a payment under the contract in French territory it would certainly bolster any argument one might care to make from a conflict of laws standpoint that French Courts should have jurisdiction to adjudicate disputes, which is technically a separate question from governing law.
If one party was there and didn't want to leave the island, one would expect that you would just sign in counterparts. It's not that likely that there is some large commercial enterprise there, so there's a pretty good chance it was a contract with the French government and the French government insisted it be signed on French soil.
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True, but the chances of a clear and unequivocal choice of law provision being altered are pretty slim. You're right though, doing it this way makes it pretty much impossible.
And the counterparts thing makes perfect sense, even after I wrote that before I thought 'you don't need to be holding hands when you sign it, so this makes no sense.'