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For purposes of determining contract interpretation, Florida courts apply the lex loci contractus choice-of-law rule. The Supreme Court of Florida observed that lex loci contractus is an inflexible rule that exists to ensure stability in contract arrangements. Under lex loci contractus, a contract (other than one for the performance of services) is governed by the law of the state in which the contract is made, i.e., where the last act necessary to complete the contract is done. But what s the last act? That s a good question to which the courts have failed to provide a clear answer. According to the Eleventh Circuit Court of Appeals, the

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