Parties en tering into a trans action which may in volve more than one coun try have to select the law un der which any dis putes aris ing out of their con tract should be set - tled. The most world- widely used and proba bly the most emi nent de vice for pre selecting a spe cific na tional law to gov ern an in ternational con tract is the so- called governing law clause1. In such a clause the …