Crawford, and Mary Keyes.<ref>The Doctrine of Renvoi in International Torts: Mercantile Mutual Insurance v Neilson (2005) 13 Torts Law Journal 1</ref> It has been suggested that this messy interpretation of the Australian Court could have been avoided, had the Court followed the general practice that procedural rules always go with the forum and substantive law depends on the "forum most interested" analysis. However, since John Pfeiffer Pty Ltd v Rogerson (2000) 203 CLR 503, statutes of limitations are considered substantive law. Because of this, the applicability of limitation laws no longer go with the local forum; rather, they too follow the lex loci delicti. United States In the United States most courts try to solve conflict of laws questions without invoking renvoi. In Re Schneider's Estate'', 96 N.Y.S.2d 652 (1950), is an example where renvoi is recognized as an option, in which the local court chose to apply the foreign country's laws to decide the dispute in the local court. This is most likely to happen in cases involving immovable property or domestic relationships. The main difficulties There are three main difficulties in cases where renvoi may be an issue: It gives undue weight to the evidence of the experts on foreign laws. The reference to the conflicts system used in other laws may reveal differences that would have arisen in characterisation or in the choice of law rules to be applied. If these differences would lead to onward transmissions, the forum court will follow the references into third (or further) legal systems. This is unpopular because it requires the parties and the court to consider evidence of multiple legal systems. There may be an "inextricable circle" between sets of laws using either single or double renvoi systems which do not have adequate safeguards built in to guarantee when to stop accepting remissions. Notes Sources Conflict of laws