Paul Lagarde’s scientific contributions

... For example, in an early article, Paul Lagarde suggested that a forum selection agreement, in the absence of other factors pointing in that direction, should not be sufficient to imply a choice of law. 192 This position has been endorsed by certain other European scholars. 193 Interestingly, the Green Paper to the Rome I Regulation states that the CJEU would likely hold that 'the mere fact of designating the courts of a country does not constitute a choice of law if this choice is not corroborated by other factors '. 194 Nevertheless, some European scholars have been critical of this view. ...

Reference:

The significance of a forum selection agreement as an indicator of the implied choice of law in international contracts: a global comparative perspective