In Auten v. Auten (308 NY 155, 160-161) the Court of Appeals developed a "center of gravity" or "grouping of contacts" approach which gave controlling effect to the law of the state that has "the most significant relationship to the transaction and the parties" (see, Restatement [Second] of Conflict of Laws 188 [1]). In addition to the traditional determinative factor of the place of contracting, the places of negotiation and performance, the location of the subject matter, and the domicile or place of business of the contracting parties are also to be considered (see, Restatement [Second] of Conflict of Laws 188 [2]).