laws of a different jurisdiction. In Canada Parties drafting contracts in Canada may indicate the laws of a specific province, followed by the phrase "and the laws of Canada applicable therein" to ensure that federal law is also applicable. Federal, provincial or territorial stature can inhibit parties' ability to negotiate a choice of law. For example, the Bills of Exchange Act, Canada Shipping Act, and the Insurance Act (Ontario). The Canadian position for autonomy for choice of law negotiations was established in Vita Food Products Inc. v Unus Shipping Co “the proper law of the contract ‘is the law which parties intended to apply.” For the choice of law clause to be enforceable, the choice of law must be bona fide, the contract must be legal, and there must be no reason for avoiding the choice of law on public policy. In order to be bona fide, the parties must not have intended to use that law in order to evade the legal system that the contract has the most substantial connection with. Where a contract which is illegal, or its performance is illegal, it will not be treated as a legal contract. The contract may also not be contrary to public policy. For example, gambling was once considered contrary to public policy, so foreign gambling debts would not be enforced in Canada. Courts may also refuse to enforce choice of law or forum selection clauses in consumer contracts where the plaintiff demonstrates strong cause that it should not be enforced, including demonstrating an inequality in bargaining power. In Canada, whether the term "submit" or "attorn" is used may determine whether the choice of law clause is enforced. In Naccarato v Brio Beverages Inc. a Court of Queen's Bench in Alberta found that the term "submit" indicated that the clause was permissive, giving the Court concurrent jurisdiction to hear the matter. In Forbes Energy Group Inc. v. Parsian Energy Rad Gas, 2019 ONCA 372, the Ontario Court of Appeal held that the clause (“attorn to the courts of England”) meant that the laws of England would apply, but the clause was not sufficient to provide the courts with exclusive jurisdiction. The action was allowed to proceed in Ontario. The term "exclusive" and other mandatory language provides more certainty that another court will not assume concurrent jurisdiction. In the United States How choice of law clauses are interpreted may vary by