This decision refuses to enforce a Utah choice of law clause in a credit card agreement, the credit card having been used to buy a motorcycle in California. While the choice of Utah law was reasonable since that is where the card issuer was located, application of Utah law would offend fundamental California public policy as expressed in McGill v. Citibank, N.A. (2017) 2 Cal.5th 945 because Utah law did not provide for public injunctions to halt unfair business practices. McGill holds that any contractual waiver of the right to seek a public injunction under the UCL violates fundamental California public policy, and the choice of Utah law had that effect. California had a materially greater interest in the application of its law to the sale of a motorcycle in this state than Utah did in that transaction.