In Sydney Attractions Grp. Pty., Ltd. v. Schulman, 74 AD3d 476 [1st Dept 2010] the defendant was not a business but an individual with a dispute with a Australian company, the plaintiff, over a deed. (74 AD3d at 476). The Sydney Attractions Court noted that the forum selection clause requiring that disputes be resolved in the Courts of the State of New South Wales and of the Commonwealth of Australia could not be unilaterally waived by the plaintiff because it was not only for the plaintiff's benefit but also for the other Australian company that was a party to the contract. (Id.).