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 Conflict of Laws
Courts typically look for a "sufficient connection" to the forum. This could be where the defendant resides, where a contract was signed, or where a car accident occurred. The doctrine of forum non conveniens often comes into play here, allowing a court to stay or dismiss a case if another forum is significantly more appropriate for the interests of the parties and the ends of justice. 2. Choice of Law: Which law applies? The law of the place where the contract was made