governing law = proper law = loi applicable (F) = normas juridicas aplicables (Esp.) : (1) the law or rules of law applicable to (distinguish) arbitration agreement, arbitration as such (including proper constitution of arbitral tribunal, jurisdiction, and arbitrability), procedure before the arbitral tribunal, extra-contractual liability, or other substantive questions such as capacity to make a contract, contractual claims
(2) only to contractual claims, Private international law, conflict of laws