2249659 Ontario Ltd. v. Sparkasse Siegen, 2013 ONCA 354 holds:
 Forum selection clauses in an agreement between parties, particularly sophisticated commercial parties, will normally be enforced by Ontario courts. A plaintiff who seeks to litigate in Ontario, having agreed that the dispute would be litigated in another forum, carries a heavy burden and must show a "strong cause" for departing from the terms of the agreement: Z.I. Pompey Industrie v. ECU-Line N.V., 2003 SCC 27,  1 S.C.R. 450, at para. 20; Expedition Helicopters Inc. v. Honeywell Inc., 2010 ONCA 351, 100 O.R. (3d) 241.