This rule figures explicitly in the French civil code (Art 1156).The subjective interpretation which nominally
directs French courts is, however, qualified in several ways. It is interpreted in an objectivized sense and constrained
by “law, usage and good faith”.23 Unexpressed unilateral intentions do not count. What matters in practice is how
the meaning was understood by the other party or how a reasonable partner would understand the term. There are
often other objective rules to be applied as well.