• This theory is credited to Walter Wheeler Cook, who expounded it in the first chapter of his Logical and Legal Bases of the Conflict of Laws (1949).
local law theory
Conflict of laws. The view that, although a court of the forum recognizes and enforces a local right (that is, one created under its own law), in a foreign-element case it does not necessarily apply the rule that would govern an analogous case of a purely domestic character, but instead takes into account the law of the foreign country by fashioning a local right as nearly as possible upon the law of the country in which the decisive facts have occurred.