applied in circumstances where in massachusetts residents with a which is mr alpert and is drilled with a long standing relationship with a large international hotel chain starwood based in connecticut seriously the most significant interest was in massachusetts then the district court could apply connecticut law it did not need to because there was no conflict but it didn't mean it still had to take into account the conflict between massachusetts and mexico but you did not do it took my representation that connecticut would apply between connecticut massachusetts as not indicating that massachusetts interests and be considered it acknowledged in it decision that there were three forms that had to be considered connecticut mexico and massachusetts but in its decision it dismissed massachusetts interest because i had my indication that i wouldn't analysis is that the court ignored the fact that the place of the relationship between massachusetts and connecticut it was not mexico the court said it was applying connecticut law you focused on their tort claims that arose from events occurring in mexico would undermine mexico sovereignty in its ability to regulate transport interests tree industry and is looking for a uniform ru e that applying the a law of the state of residence of individuals visiting in a foreign place would not promote uniformity predictability and wouldn't manage people's expectations appropriately so it seemed to me that he did take into account the possibility of applying either connecticut or massachusetts law to that dismissed them both with i would i would disagree  its residents stay and an american company so tell and this that it's going to have the same states the standards whether that that american company is in the united  country's nd it has an interest in its residents getting being compensated properly and in this case massachusetts mexico has significant bars to individuals painting and station and that's the concept there are two cases in connecticut that i think control here that the court really didn't address remember this is connecticut choice of war says no these are not residents of the place of the injury the interests of the state where they are resident predominates we have no interest no interest in giving the water remedies to residents of those jurisdictions their policy let me ask you this question what were the interests of mexican with the interest in applying mexican law  that's where mexico's interest become more arguably predominant because in that case certainly met school has an interest in regulating and protecting its own companies its own citizens and so named the owner of the resort and the manager facilities then with respect to the exact same accident different law would apply there be a lot of differences i'm not sure that there would be that this case has a management agreement with a mexican entity and in fact that management agreement which is at issue limits case which regards to the various resort the claims that they may be made in this case which is outlined in judge under her decision on page one there was activity except for the possibly  companies doing interstate and international business have to get with different applications of the laws all the time so once again the poor ism issue is overstated i would point in my brief to the judge case and the which reject the tourism argument in favor of the argument that i'm making that massachusetts interest in the providing safety for its citizens when they have a relationship with an american resort and providing a full remedy that's completely inaccurate as i indicated there is a longstanding relationship this was that they use the starwood brands of all their vacation their relationship for that was that wherever they traveled around the world they were entitled to have to lock their domicile government starwood with be in all three sorts around the world with the subject to kentucky connecticut whenever wherever just depending on where the visitor came from said right i'm saying that in this particular case if you do the analysis because what happens here is because it's only an american corporation an american plaintiff and in mexico that the areas of the conflict are comparative negligence and a much stricter causation standard which are far the plaintiff mr alpert and his wife and much reduced to get the maximum benefits so there could be other cases in different jurisdictions where the analysis is different i just know in this one because those differences prevent my clients from bringing a claim and what should massive mexico's interest is much reduced when the claims none of the citizens or its residents are involved in the litigation