In M S Bremen v. Zapata Off-Shore Co., 407 U.S. 1 (1972), a tug owner brought a limitation of liability action. The owner's contract to tow a barge from Louisiana to Italy contained a forum selection clause, designating London as the forum to hear disputes. The Court stated that forum selection clauses are enforceable unless the claimant clearly shows that "enforcement would be unreasonable and unjust, or that the clause was invalid for such reasons as fraud or overreaching." Id. 407 U.S. at 15. Additionally, "a contractual choice-of-forum clause should be held unenforceable if enforcement would contravene a strong public policy of the forum in which suit is brought, whether declared by statute or judicial decision." Id. The Supreme Court held that a forum selection clause should be enforced unless it can be clearly shown that "enforcement would be unreasonable and unjust, or that the clause was invalid for such reasons as fraud or overreaching" or "if enforcement would contravene a strong public policy of the forum in which suit is brought..." Bremen, 407 U.S. at 15 (1972). Further, the Supreme Court stated that in light of present-day commercial realities and expanding international trade we conclude that the forum clause should control absent a strong showing that it should be set aside." Id.