Party autonomy is well established as a fundamental principle of international dispute resolution. Most legal systems enforce express choices of arbitration, jurisdiction, and law, at least in cases which do not involve protective concerns. Most legal systems also refer to the concept of implied agreements, both in choice of law and in jurisdiction. Implied agreements historically played a dominant role in the context of choice of law, particularly for choice of law for contract and marital property agreements. Indeed, until the 20th century, most references to party autonomy in the context of choice of law were to implied, rather than actual, choices.' Implied choices in the context of jurisdiction in international litigation play a different, more obscure role. Whereas implied choices of law are mutual choices of the contracting parties, most implied choices in the jurisdictional context are unilateral. This article focuses on unilateral choices that arise from the conduct of the defendant.