The problem of ascertaining the applicable law is more perplexing in the case of contracts than in almost any other area. There are three reasons for this. First, there is the diversity of connecting factors that can be raised by the facts of the case: the place where the contract is made; the place of performance; the domicile, nationality or place of business of the parties; the situation of the subject matter and so on. In most areas of private international law the decisive connecting factor on which ascertainment of the applicable law depends is reasonably...
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