The reform confers upon the courts, inter alia, the power to modify a contract in the event of an unforeseen change in circumstances (“imprévision”); this innovation appears at first sight to be significant. It is not however certain how case law will deal with this, and courts may prefer to terminate a contract, as the law allows them to in the alternative. Furthermore, since this is not a public policy provision, hardship clauses, which are frequent in an international context, should be sufficient to dispose of this. The influence of the new article 1195 of the Civil Code should therefore probably be marginal, but not null. This leads one to consider the limits and the spirit of the powers so granted; arbitrators would seem to be better placed than state courts to apply these.