The theory of the rules of immediate application represents a functional trend in continental Private International Law system. In 1958, Francescakis observed the phenomenon of the rules of immediate application in France, and Currie observed the “govemmental interest analysis” in the United States at the same time. Although these two choice-of-law approaches have little to do with reciprocal influence, however, these two choice-of-law approaches are both functional approaches which are on the basis of the under1ying policies of substantive rules and give great influence in their Private International Law system. Undoubtedly, the dichotomy between the “rules of immediate application” approach and the “conflict rules” approach is a fact. It cannot be denied that substantive rules of each state exists claiming application in view of their content, purpose and underlying policy and irrespective of normally applicable law. And when the courts determine to apply a substantive rule immediately, they should take into account not only the immediate application of forum substantive rules but also the immediate application of foreign substantive rules. Therefore it is increasingly forming a systematic choice-of-law approach regardless of the conf1ict rules. The “immediateapplication-of-a-substantive-rule” approach is so-called the rules of immediate application. In so far a certain bifurcation of choice-of-law approach in continental Private International Law has to be admitted, and the bifurcation in fact is necessary just of the needed distinction of the nature of two approaches and a functional thinking.