In an action filed by Andina Licores S.A. (“Andina”), an Ecuadorian corporation, against E & J. Gallo Winery (“Gallo”), one of the largest wineries from California, the Second Civil Court of Guayaquil found that it lacked jurisdiction to hear the dispute because both parties had agreed in their distribution contract that their controversies must be heard by a California court and in accordance to California law.