Evolution Online Systems, Inc. v. Koninklijke Nederland N.V.
This case, on remand from the Second Circuit, involves claims of breach of contract, copyright infringement, and quantum meruit. The Court had previously dismissed the complaint, citing a forum-selection clause mandating litigation in the Netherlands. The Second Circuit remanded to clarify whether a contract with such a clause existed and if it should be enforced, or if dismissal was appropriate on forum non conveniens grounds. The District Court affirmed that a binding contract with a mandatory Netherlands forum-selection clause existed and should be enforced due to significant partial performance and mutual intent to be bound, despite the lack of a signed document. The court also determined that even without the clause, the case would be dismissed on grounds of forum non conveniens, as the Netherlands offers an adequate alternative forum and is more convenient based on public and private interest factors, including the location of proof and the applicability of Dutch law.