Cowboy, Inc., an American corporation that produces cowboy hats contract with a manufacturing plant in France, Beret, Inc. The contract provides that Beret, Inc. will produce the cowboy hats in France to be distributed back in the United States by Cowboy, Inc. The contract does not provide which country’s law will apply if a dispute arises between Cowboy and Beret. Eventually, Cowboy discovers that Beret is not producing the hats under the specifications agreed upon in the contract. Which will American or French law be used in settling the dispute? Why?

When companies from different countries get into a contract, it is quite desirable that they stipulate which country's laws that they will abide by should the need arise.

However, if this is not done, there is still a method of enforcing. When not specifically listed, contract between companies from different countries falls under a branch of Private International law which is International Contract Law which is synonymous with International Sales law.

This law falls under the jurisdiction of the United Nations Convention on Contracts for the International Sale of Goods (CISG) which came into effect in January 1988.

Both France and the United States of America have ratified the law and so Cowboy Hats is free to take legal action within this framework if they so please.