¶ 41. {concurring). Although I join the opinion of the court, I write separately because the majority neglects to provide adequate guidance to courts and litigants in the application of the "last significant event" test.
¶ 42. This case presents the court with the question of whether a Wisconsin insurance company's refusal to pay benefits arising from a Wisconsin insured's personal injury in the State of Florida may constitute a "foreign cause of action" pursuant to Wis. Stat. § 893.07 (1993-94), requiring application of Florida law. In answering this inquiry, the majority adopts, without significant explanation, the "last significant event" test set forth in Terranova v. Terranova, 883 F. Supp. 1273 (W.D. Wis. 1995), for determining the proper state's statute of limitations laws to be applied to the contractual dispute.
¶ 43. Unfortunately for future litigants, the "last significant event" inquiry is easily resolved under the facts of this case. General Casualty is a Wisconsin corporation. Abraham is a Wisconsin resident. The negotiation and purchase of the insurance contract took place entirely within Wisconsin. Similarly, General Casualty's decision to refuse to pay Abraham's claim and the subsequent conveyance of that decision to Abraham also occurred in Wisconsin. Thus, every significant factor that might be considered determinative in a "last significant event" test argues in favor of applying Wisconsin law to this case.
¶ 44. Subsequent cases, however, may not present themselves in such an accommodating manner. In adopting the "last significant event" test based on these homogenous facts, the majority not only fails to provide our courts with a cogent set of rules or standards with which to evaluate breach of contract cases that more *315directly implicate the interstate sale of insurance contracts or the mobile nature of purchasers, but also labels any such inquiry "extraneous." I fail to see how providing our courts with sufficient guidance in applying a test which the majority adopts as the substantive law of this state is in any way an "extraneous" inquiry. A series of hypothetical may be illustrative of my concern.
¶ 45. First, a Minnesota insurance company sells a policy to a Wisconsin resident and later denies her claim in writing via a letter mailed from Minnesota. Second, the same Minnesota insurance company instead mails its decision to deny coverage to an agent in Wisconsin, who then copies the letter to the Wisconsin insured. Third, a Wisconsin insurance company sells a policy in Wisconsin to a Minnesota resident who travels through the state. The Wisconsin company then denies a claim by calling the Minnesota insured when he again passes through the state of Wisconsin.
¶ 46. In each of these scenarios we are left with the same question: if the breach of contract is the last significant event, as the majority and Terranova indicate, where does that breach occur? Does it occur in the state where the party in breach is located? Does it occur in the state wherein the injured party resides? Does it occur in the state where the. insurance contract was negotiated or purchased? Does it occur in the state from which the breach is communicated? Any one of these inquiries might be the dispositive question in an attempt to determine in which state the breach of contract or "last significant event" occurred. Yet, our courts áre left to speculate.
¶ 47. Alternatively, it is possible that the majority intends our courts to consider each of the questions above and then reach a decision based on the totality of *316circumstances. If this is indeed the intent of the majority, such reasoning is inconsistent with the majority's rejection of the "center of gravity" test which employs a similar totality of circumstances approach.
¶ 48. Finally, I note that the majority explicitly rejected application of the "place of injury" and "center of gravity" tests on the grounds that such tests would overuse scarce judicial resources and "almost certainly necessitate further litigation and future decisions by this court to determine the proper standard for contract actions that remain wholly separate from tort law." Majority op. at 307. Yet, the majority acknowledges in relation to the "last significant event" test that "in certain factual situations not present here, even this test would not be without ambiguity." The majority attempts to justify its failure to resolve this ambiguity by then noting, "[hjowever, as with any judicial standard, no one "test" can give complete certainty to future litigants." Majority op. at 311, fn.7
¶ 49. This contention is simply inaccurate. The majority's failure to lay out the parameters of the "last significant event" test in contract actions does not mean that bright-line rules, or even a set of standards that might appropriately be applied, do not exist. Rather, it indicates a failure by the majority to consider the future ramifications of its vague opinion on our courts and litigants.
¶ 50. I agree with the majority's conclusion that Wis. Stat. § 893.07(1) governs contract actions and with its adoption of the "last significant event" test. However, the majority errs when it assumes such a conclusion without examination or explanation and when it fails to set out sufficient standards of application that can assist our courts and guide expectations of potential litigants. Accordingly, I concur.
*317¶ 51. I am authorized to state that Chief Justice Shirley S. Abrahamson and Justice Janine P. Geske join this opinion.