Conflict-of-Laws Engine

The input gateway that parses a multi-jurisdictional fact pattern to identify and extract the operative connecting factors. These are the legally significant contacts—such as domicile, place of injury, place of contracting, or situs of property—that link a dispute to a specific sovereign. This module transforms raw case facts into a structured jurisdictional fingerprint.

A structured, machine-readable knowledge base encoding the conflict rules of the forum state. It stores conditional logic statements, such as the lex loci delicti (law of the place of the wrong) for torts or lex loci contractus (law of the place of contracting) for contracts. This repository must handle rule versioning to account for legislative amendments and judicial reinterpretations over time.

The logical processor that performs subject-matter characterization. Before a choice-of-law rule can be applied, the legal issue must be classified into a juridical category (e.g., tort, contract, property, succession). This module resolves the preliminary question of whether a claim for fraudulent misrepresentation sounds in tort or contract, which dictates the applicable connecting factor.

A specialized sub-system that detects and resolves renvoi (ping-pong) scenarios. When the forum's choice-of-law rule points to a foreign jurisdiction, this module determines whether the reference includes that foreign state's conflict rules. It algorithmically prevents infinite loops by applying either single renvoi (accepting the remission) or double renvoi (the foreign court theory), based on the forum's doctrinal stance.

A safety mechanism that acts as a terminal check on the selected applicable law. Even if all connecting factors point to a foreign jurisdiction, this module evaluates whether the application of that foreign law would violate a fundamental public policy of the forum state. It serves as a hard constraint, capable of nullifying the engine's primary output to prevent repugnant or unconstitutional outcomes.

An advanced analytical module that implements dépeçage, the process of applying different jurisdictions' laws to different issues within a single case. Rather than selecting one governing law for the entire dispute, this component dissects the case into severable issues—such as liability, damages, and defenses—and independently applies the appropriate law to each, maximizing granularity in complex litigation.