CONFLICT OF LAWS.--SUBSTANCE OR OBLICATION OF CONTRACT DISTINGUISHED FROM REMEDY.

This article focuses on the conflict of laws. One of the most puzzling of the many difficult points that beset the student of the Conflict of Laws is that of determining whether a particular question forms part of the substance or obligation of a contract, to be governed by the lex loci, or whether it is one of remedy merely, to be controlled by the lex fori. The substance or obligation of a contract embraces all the rights and liabilities that result expressly or impliedly from the agreement and understanding of the parties everything within the view and intention of the parties when they enter into their contract.