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2d Cir 5th Cir accident adhesion contracts adopted agreement American Law American Law Institute cert choice of law claim clauses common law concerning Conflict of Laws conflicts law conflicts rule Corp damages decision defendant's denied doctrine domestic domicile domiciliary effect eign enterprise liability Estate F.Supp faith and credit favor federal flicts foreign law formulae forum law forum statute fraud full faith governing guest statute infra interest interpretation judicial jurisdiction land law of conflict law rules lex contractus lex fori lex loci lex situs limited marriage ment personal law place of contracting place of wrong plaintiff presumption of validity prevailing problems protection purport question reached Recueil regard renvoi require rules of choice S.Ct Second Restatement significant relation significant relationship spouses supra Supreme Court theory third parties tion tort transaction trust Uniform Uniform Commercial Code usually York Court