In international arbitration, lex officii takes a modified form. Arbitral tribunals are not state courts, so they typically apply agreed-upon procedural rules (e.g., ICC or UNCITRAL rules). However, they remain subject to the mandatory procedural laws of the seat of arbitration (the lex arbitri ), which functions as a lex officii of the juridical seat. Despite its utility, lex officii is not without critics. Over-reliance on forum law can lead to forum shopping , where plaintiffs rush to courts whose procedural rules (e.g., broad discovery, jury trials, contingency fees) favor their case. Worse, a court applying its own procedural rules may inadvertently discriminate against foreign parties—for instance, by imposing evidentiary standards impossible to meet under the foreign legal system.