Like other ordinary law doctrines, conflict rules vary from state to state. Most States will not have recourse to a choice provision that would be contrary to the public policy of a State that has a „much greater interest“ in the dispute or if the parties do not have an „essential relationship“ with the elected State. In other words, a California employer cannot circumvent California`s prohibition of restrictive agreements for workers by requiring its California employee to sign an agreement containing a Nevada choice clause. Already in Dyer`s Case in 1414, English Common Law decided not to impose restrictions of competition because of their nature as trade restrictions.  This prohibition remained unchanged until 1621, when it became apparent that a restriction limited to a given geographical location constituted an enforceable exception to the previous absolute rule. . . .