the lex fori. The Characterising laws as either procedural or substantive is necessary, but that part of the process can be abused by the forum court to maximise the use of the local law. The generality of the characterisation process is not and cannot be wholly scientific. It is always a matter of interpretation. For example, if A, who is a national of Arcadia, dies having made a valid local will and leaves land situated in Barsoom to C, who is domiciled in Catilage, how is the issue to be classified? One might say that any rights that C might have are vested by the will that was made in Arcadia, the lex loci actus. Equally, the right to succeed to title might be an aspect of C's status as the oldest surviving male heir under Cartilagean law, the lex loci domicilii. Also, it may be a matter for the law of Barsoom since all matters of title to land must be adjusted by the lex situs, as the law of the place of the land. Thus, completely different judgments might result depending on how the forum court characterises the action. One of the most enduring solutions to this problem was proposed by Friedrich Carl von Savigny (1779–1861). He argued that it was always necessary for the court to find the "natural seat" or "centre of gravity" for the case by identifying the largest cluster of "connecting factors" to a particular legal system. If all courts adopted such an international outlook, he reasoned, that would eliminate forum shopping by producing the same choice of law no matter where the case began. Unfortunately, the theory has not delivered the desired results. Forum shopping remains a problem, and neither legislators nor judges have been able to agree on characterisation issues, producing classifications that extend rather than reduce international divergences. In an attempt to avoid obviously unjust results in particular cases, some judges have created a number of public policy exceptions to justify decisions "on the merits". Ernest G Lorenzen commented that the strategy was a warning that there must be serious problems with the rules if policy exceptions were the solution. Under European Union Regulations Choice of law characterisation within the European regime relating to civil and commercial matters is determined by the Rome I Regulation and Rome II regulation. The Rome I regulation, succeeding the Rome Convention regulates choice of law