In a ruling that may be of interest to any company that includes forum selection clauses in its agreements—especially in agreements with consumers—the US Court of Appeals for the Ninth Circuit recently ruled that a clause selecting the "courts of Virginia" meant the parties agreed to litigate only in Virginia state courts, not its federal courts. Doe 1 v. AOL LLC, No. 15323 (9th Cir. Jan. 16, 2009).