A collection of the most recent US international arbitration decisions is available here. Decisions can be quickly retrieved by using the filter tools below.
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Adk Plaza-Centrum, LLC v. Independent Specialty Insurance Company, No. 3:23-CV-01405-SDD-EWD (M.D. La. July 11, 2024)07/11/2024
Court granted defendants’ motion to compel arbitration against plaintiffs, finding that all four requirements for enforcing an arbitration clause under the New York Convention are met: (1) there is a written arbitration agreement, (2) the agreement provides for arbitration in New York and the United States is a New York Convention signatory, (3) the agreement arises out of a commercial relationship between the parties, and (4) two of the defendants are not American citizens. Court acknowledged that the plaintiffs maintained separate contracts with the foreign and domestic insurers, but where the operative policy language across contracts was nearly identical, the court found that equitable estoppel applied and required the court to compel arbitration.
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Wallrich v. Samsung Electronics America, Inc., No. 23-2842 (7th Cir. July 1, 2024)07/01/2024
Court of appeals denied appellants’ motion to compel arbitration because consumers failed to show an arbitration agreement existed. To show an arbitration agreement existed, consumers only needed to show they were Samsung customers. Evidence of an AAA request for arbitration, spreadsheet with names and address, copies of Samsung’s terms and conditions, and the AAA’s determination that filing requirements had been met were insufficient proof of the parties’ arbitration agreement. Additionally, court of appeals denied request to compel appellees to pay the AAA’s administrative fees, finding that because there was no arbitration agreement, the AAA’s rules and procedures which granted the tribunal discretion in resolving fee disputes were irrelevant. Moreover, even where the parties agreed to abide by the rules of the AAA, the AAA has exclusive discretion over its fee disputes.
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Teta v. Go New York Tours, Inc., No. 1:24-CV-01614-ER (S.D.N.Y. July 1, 2024)07/01/2024
Court granted defendants’ motion to compel arbitration, finding that the parties were bound by a “clickwrap arbitration agreement” within the contract’s terms and conditions where the parties had “reasonable notice of the arbitration provision.” To determine whether there was reasonable notice, the court relied on the fact that plaintiffs had to affirmatively click their assent to the agreement and that the terms and conditions were hyperlinked.
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Garage Door Systems, LLC v. Blue Giant Equipment Corp., No. 1:23-CV-02223-JMS-KMB (S.D. Ind. June 20, 2024)
06/20/2024Court found that a Rule 12(b)(3) motion to dismiss for improper venue, rather than a motion to stay or compel arbitration, is the proper procedure to use when an arbitration clause requires arbitration outside a district court’s district. Court then denied defendant’s motion to dismiss for improper venue, finding that a vague reference to the Terms and Conditions in the Order Acknowledgements was not sufficient under the United Nations Convention on Contracts for the International Sale of Goods to render the clause part of the parties' agreement. As a result, the arbitration provision contained in the Terms and Conditions was not part of the parties' agreement.
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Queen-Gilbertson v. U.S. Auto Sales, Inc., No. 23-CV-03331-DCC (D.S.C. June 20, 2024)06/20/2024
Court granted defendants’ motion to compel arbitration, denied motion to dismiss, and denied motions for protective order and to stay discovery as moot. Court concluded that arbitration agreement was valid and enforceable and that delegation clause provided that issues of arbitrability would be decided by arbitration.
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Ghazizadeh v. Coursera, Inc., No. 23-CV-05646-EJD (N.D. Cal. June 20, 2024)06/20/2024
Court granted defendant’s motion to compel arbitration and stay pending arbitration. Court concluded that an arbitration agreement was formed where plaintiff manifested assent to the website’s terms of use on a sign-up screen, the terms of use contained a provision indicating that continued use signaled assent to updated terms, and website provided sufficient notice of the updated terms of use containing the arbitration agreement in an email.
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Williams v. Wallace Finance, LLC, No. 24-CV-00662-D (N.D. Tex. June 18, 2024)06/18/2024
Court granted defendant’s motion to compel arbitration and stay the proceedings pending arbitration. Court found that defendant did not waive its right to arbitrate and further found that the agreement to arbitrate was valid where plaintiff failed to reject the agreement as warranted under the agreement.
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Jonna v. Bitcoin Latinum, No. 22-CV-10208-LJM-JJCG (E.D. Mich. June 17, 2024)06/17/2024
Court denied defendants’ motion to compel arbitration and stay proceedings where plaintiffs did not read or sign the arbitration agreement, nor could plaintiffs assent to the agreement be inferred from conduct. Court further found that the issue of arbitrability could not be delegated to an arbitrator where no valid arbitration agreement existed and that, even if an agreement existed, defendants waived their right to enforce arbitration by engaging extensively in litigation.
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LAG Oasis, LLC v. Independent Specialty Insurance Co., No. 23-CV-06584-NJB-DPC (E.D. La. June 13, 2024)06/13/2024
Court granted defendants’ motion to compel arbitration and stay litigation, but denied the motion to dismiss plaintiff’s claims in light of the Supreme Court’s recent decision in Smith v. Spizzirri. Court concluded, in line with Fifth Circuit’s precedent, that where the arbitration agreement was housed within a broader insurance contract, the arbitration clause need not be signed by the parties to satisfy the requirements of the FAA and NY Convention. Court further did not consider the arbitration clause to be against public policy.
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Arigna Technology Ltd. v. Longford Capital Fund, III, LP, No. 23-CV-01441-GBW (D. Del. June 5, 2024)06/05/2024
Court granted defendant’s motion to compel arbitration and denied plaintiff’s motion to enjoin arbitration as moot. Court found that defendant, as a non-signatory third party to arbitration agreement, could compel arbitration because the agreement assigned arbitrability disputes to arbitrator, the agreement incorporated a second agreement with defendant by reference, and defendant was third-party beneficiary to arbitration agreement.
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Marshall v. Ameriprise Financial Services, No. 24-CV-00112-DJC-AC (E.D. Cal. May 31, 2024)05/31/2024
Court granted in part defendant’s motion to compel arbitration and stay pending arbitration. Court held that the arbitration agreement was enforceable against plaintiff where plaintiff was dyslexic and their fiduciary failed to orally explain the material terms of the parties’ agreement, including the arbitration agreement. The agreement was however binding on the trustee, where the same circumstances did not exist. Court further struck the agreement’s unconscionable provision which unfairly limited plaintiff’s recovery.
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Shenzhen Xingchen Xuanyuan Industrial Co. Ltd. v. Amazon.com Services LLC, No. 23-CV-06549-GHW (S.D.N.Y. May 30, 2024)05/30/2024
Court granted motion to stay and compel arbitration where the AAA previously closed an arbitration between the parties due to the plaintiff’s nonpayment of arbitrator fees. Court found it would not sidestep the parties’ arbitration agreement where the arbitration process had not “been had” under Section 3 of the FAA. Additionally, a party cannot avoid a mandatory arbitration clause by refusing to pay arbitrator fees.
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3131 Veterans Blvd, LLC v. Indian Harbor Insurance Co., No. 24-CV-00753-CJB-DPC (E.D. La. May 23, 2024)05/23/2024
Court granted motion to stay proceedings for breach of the parties’ insurance policy where an appeal to the Second Circuit for the denial of defendant’s motion to compel arbitration remained pending. The Southern District of New York denied defendant’s motion to compel, finding that arbitration agreements in insurance contracts were invalid under Louisiana law. However, the Fifth Circuit recently clarified that La. R.S. 22:868 does not apply to treaties and therefore does not reverse-preempt the New York Convention. Accordingly, the Louisiana district court found, a stay here was warranted where defendants would lose the ability to enforce the arbitration agreement if the stay was not granted.
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Thyssenkrupp Materials NA, Inc. v. Pegasus Denizcilik A.S., No. 23-CV-03086 (N.D. Ill. May 17, 2024)05/17/2024
Court denied defendants’ motion to dismiss for improper venue based on an arbitration agreement where plaintiff was not a signatory to the arbitration agreement and the arbitration clause was not sufficiently incorporated into the parties’ contract through specific reference. Focusing on the Seventh Circuit’s limited caselaw on the meaning of “specific reference,” the court affirmed that the contract must at least identify the date of the arbitration agreement to incorporate the clause.
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The Cherokee Nation v. OptumRX, Inc., No. 23-CV-00259-RAW-GLJ (E.D. Okla. May 8, 2024)05/08/2024
Court recommended that defendants’ motion to stay the litigation pending arbitration should be granted pursuant to § 3 of the FAA. Court’s recommendation was based on clear evidence that the parties delegated the issue of arbitrability to the arbitrator, and thus that challenges to the arbitration provision’s enforceability must be resolved by the arbitrator. Accordingly, questions as to the tribal nation’s waiver of its sovereign immunity, whether the arbitration provision was unconscionable, and whether the Recovery Act precluded arbitration must be resolved by the arbitrator.
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Chubb Capital I Limited v. New Orleans City, No. 23-CV-05806-JTM-KWR (E.D. La. May 6, 2024)05/06/2024
Court granted plaintiff’s motion for a preliminary injunction to enjoin defendant from bringing arbitration proceedings, finding that plaintiff showed a substantial likelihood of success on the merits, a substantial threat of irreparable harm, the threatened injury outweighed the threatened harm to defendant, and there would be no disservice to the public interest. Focusing on plaintiff’s likelihood of success, the court determined that plaintiff did not consent to arbitration, none of Louisiana’s common law bases for compelling a non-signatory to arbitrate were applicable, and Louisiana’s Direct Action Statute would hold that third-party insurers would not be compelled to submit to binding arbitration under the circumstances.
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Support Community, Inc. v. MPH International LLC, No. 23-CV-04911-JSW (N.D. Cal. May 2, 2024)05/02/2024
Court denied the motion to compel arbitration of defendant and counterclaimant, reasoning that, although there was an agreement to arbitrate between the parties, plaintiff met its burden of demonstrating that defendant and counterclaimant had waived its right to arbitrate because under the “totality of the circumstances” it had acted inconsistently with its known right to compel arbitration.
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Compleat Hospitality Management, LLC v. Independent Specialty Insurance Company, No. 2:23-CV-04032-BSL-KWR (E.D. La. Apr. 19, 2024)04/19/2024
Court granted defendants’ motion to compel arbitration and stayed the proceedings. Court found that while Louisiana state law prohibits arbitration agreements in insurance contracts, that law is preempted by the New York Convention. Court further found that each element required to compel arbitration under the New York Convention was met.
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Foundation Church Inc. v. Independent Specialty Insurance Company, No. 23-CV-02847-CEH-J_S (M.D. Fla. Apr. 11, 2024)04/11/2024
Court granted motion to compel arbitration and stay the case pending arbitration where the parties’ insurance contract contained an arbitration clause, and the four jurisdictional factors were satisfied under the New York Convention.
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Nemo Digital Holdings Corp. v. XYZ Financial Markets LLC, No. 2:24-CV-00737-EP-JSA (D.N.J. Apr. 11, 2024)04/11/2024
Court granted defendants’ motion to compel arbitration on the grounds that plaintiff alleged the entire agreement between the parties was procured by fraud but did not specifically argue that the arbitration agreement was procured by fraud. Court denied defendants’ motion for attorneys’ fees, reasoning that it could not determine who was considered a prevailing party at that stage, considering the opinion was a preliminary procedural order.
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Fli-Lo Falcon LLC v. Amazon.com, Inc., No. 22-35818 (9th Cir. Apr. 10, 2024)04/10/2024
Court of appeals affirmed the district court’s opinion granting motion to compel arbitration, reasoning that the transportation worker exemption under Section I of the FAA does not extend to business entities or commercial contracts. Court of appeals found the delegation provision in the arbitration clause was not unconscionable, as it was between sophisticated parties, so plaintiffs’ unconscionability arguments directed at the arbitration agreement as a whole must be decided by the arbitrator.
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Royal White Cement, Inc. v. Weco Holli M/V, No. 23-CV-00788-BSL-DPC (E.D. La. Apr. 9, 2024)04/09/2024
Court granted in part motions to compel arbitration and to stay case pursuant to the New York Convention and denied in part motions to stay, insofar as they sought to stay the case in its entirety as to claims and parties not subject to the arbitration agreement.
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Eaton v. Ascent Resources-Utica, LLC, No. 19-CV-03412-EAS-CMV (S.D. Ohio Apr. 4, 2024)04/04/2024
Court granted defendant’s motion to modify the class definition to exclude members of a certified class of property owners who had binding arbitration provisions in their lease agreements. Court reasoned that defendants did not waive their right to arbitrate based on their participation in the litigation because evidence regarding the arbitration agreements of non-class representatives was not available before the class certification stage, and the existence of arbitration agreements between class members and defendant had the potential to destroy the typicality and adequacy requirements of Federal Rule of Civil Procedure 23(a).
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St. James Parish School Board v. Certain Underwriters at Lloyd’s, No. 23-CV-06638-BSL-MBN (E.D. La. Apr. 1, 2024)04/01/2024
Court granted defendant’s motion to compel arbitration and stay litigation where all four factors of the New York Convention had been met: the parties entered into a written agreement to arbitrate, the agreement provides for arbitration in a New York Convention signatory nation, the agreement arises out of a commercial legal relationship, and the respondent is a non-American citizen and party to the arbitration agreement.
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Sunbelt Innovative Plastics, LLC v. Certain Underwriters at Lloyds, London, 23-CV-06194-BSL-JVM (E.D. La. Apr. 1, 2024)04/01/2024
Court granted defendant’s motion to compel arbitration and stay litigation where it found all four factors of the New York Convention had been met: the parties entered into a written agreement to arbitrate, the agreement provides for arbitration in a New York Convention signatory nation, the agreement arises out of a commercial legal relationship, and respondent is a non-American citizen and party to the arbitration agreement.
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Jubilant Generics Limited v. Dechra Veterinary Products, LLC, 2:23-CV-00237-JDL (D. Me. Mar. 28, 2024)03/28/2024
Court granted plaintiff’s motion to compel ICC arbitration of defendant’s counterclaims, holding the issue of waiver was for the court to decide because it was based on litigation conduct and that plaintiff had not waived its right to compel arbitration because its claims fell within an exemption to the arbitration provision in the parties’ underlying agreement, and the parties were required to litigate in two forums to give effect to the arbitration agreement under the FAA.
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Chifici Enterprise D/B/A Deanie’s Seafood v. Certain Underwriters at Lloyd’s London, No. 2:23-CV-05764-JTM-MBN (E.D. La. Mar. 27, 2024)03/27/2024
Court granted defendants’ motion to compel arbitration and stay the proceedings, holding that all four requirements of the New York Convention were met. Although at least one party to the agreement was not a foreign or non-American citizen, court granted the motion, holding that plaintiffs were equitably estopped from objecting to arbitration because their underlying claims alleged misconduct among the various defendants, who included foreign citizens, that was interdependent and in concert.
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Landbridge Port Services (Hong Kong) Ltd. v. Notarc Port Investment LLC, 1:24-CV-00254-GBW (D. Del. Mar. 27, 2024)03/27/2024
Court granted plaintiff’s motion to remand to Delaware state court, holding, in agreement with the Second Circuit, that § 205 of the FAA does not independently confer subject matter jurisdiction. Court found that it also did not have federal question jurisdiction under § 203 of the FAA, because it was an action to enjoin an arbitration in Panama instead of a motion to compel arbitration or enforce an award.
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Stonelake Condominium Association, Inc. v. Certain Underwriters at Lloyd’s London, 3:23-CV-00279-JWD-SDJ (M.D. La. Mar. 27, 2024)03/27/2024
Court granted defendants’ motion to compel arbitration and stay the proceedings, holding that the arbitration agreement was covered by the New York Convention and thus could not be reverse preempted by a Louisiana state statute prohibiting arbitration clauses in insurance contracts. Court held further that the New York Convention was applicable to all defendants, including US citizen defendants, because the underlying claims alleged that all defendants acted “interdependently and in concert.”
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Vitol, Inc., v. Copape Produtos de Petroleo LTDA, No. 22-CV-10569-JPC (S.D.N.Y. Mar. 21, 2024)03/21/2024
Court granted petitioner’s motion to compel arbitration and denied respondent’s cross-motion to dismiss the action. Court found that, although respondent was not a signatory to the relevant contracts, respondent was estopped from refusing to be bound by the arbitration clauses contained therein because it directly benefited from the contracts.
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Concept Engineering LLC v. Pinterest, Inc., No. 21-CV-01465-MN (D. Del. Mar. 20, 2024)03/20/2024
Court granted defendant’s motion to stay action pending arbitration finding whether a non-signatory can compel plaintiff to arbitrate is a question of arbitrability which was delegated to the arbitrator by “clear and unmistakable” evidence.
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Allianz Risk Transfer (Bermuda) Limited, v. High Lonesome Wind Power, LLC, No. 22-CV-05133-GHW (S.D.N.Y. Mar. 19, 2024)03/19/2024
Court granted defendant’s motion to compel arbitration finding the parties’ arbitration agreement unambiguously requires the arbitration of their dispute regarding the calculation of the amount due under the contract.
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Cephea Valve Technologies, Inc. v. Abbott Laboratories, No. 23-691-GBW-SRF (D. Del. Mar 18, 2024)03/18/2024
Court recommended that the district court grant defendant’s motion to compel arbitration and dismiss the complaint with prejudice upon concluding that the underlying arbitration provision was not ambiguous, unconscionable, or invalid due to fraud. Court further found that certain counts in the complaint fell within the scope of the arbitration provision, which broadly covered “any dispute arising under” the at-issue agreement.
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McBurnie v. RAC Acceptance East, LLC, No. 22-16868 (9th Cir. Mar. 14, 2024)03/14/2024
Court of appeals affirmed district court’s denial of motion to compel arbitration finding that defendant’s arbitration agreement was unenforceable under a California law invalidating contracts that waive the right to seek injunctive relief on behalf of the general public, and that California law was not preempted by the FAA. Court of Appeals further found that its prior decision was not abrogated by the subsequent Supreme Court decision in Viking River because that decision dealt with a different California law.
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Anhui Powerguard Technology Company, Limited v. DRE Health Corporation, No. 23-1820 (8th Cir. Mar. 14, 2024)03/14/2024
Court of appeals affirmed district court’s denial of motion to stay litigation and compel arbitration under the FAA. Court of appeals determined that the parties did not agree to submit their dispute to arbitration where the arbitration agreement included a condition precedent which was not satisfied.
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Bufkin Enterprises, L.L.C. v. Indian Harbor Insurance Company, No. 23-30171 (5th Cir. Mar. 4, 2024)03/04/2024
Court of appeals reversed district court’s denial of appellants’ motion to compel arbitration under the New York Convention. Court of appeals found that the doctrine of equitable estoppel under Louisiana law compelled arbitration because the appellee signatory to the arbitration agreement raised allegations of substantially interdependent and concerted misconduct by both non-signatory appellants and one or more of the signatory appellants to the arbitration agreement, even though the complaint later dismissed the signatory appellants as defendants.
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Chicken Mart, Inc. v. Independent Specialty Insurance Company, No. 23-CV-06661-EEF-JVM (E.D. La. Feb. 23, 2024)02/23/2024
Court granted motion to compel arbitration and stayed litigation pending arbitration, finding that the requirements of the New York Convention were satisfied. Court compelled arbitration between foreign and domestic defendants because plaintiff was alleging intertwined conduct on the part of all defendants.
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Apex Hospitality Group, LLC v. Independent Specialty Insurance Company, No. 23-CV-02060-JTM-JVM (E.D. La. Feb. 23, 2024)02/23/2024
Court granted motion to compel arbitration, finding that the requirements of the New York Convention were satisfied. Court found that plaintiff was equitably estopped from objecting to arbitration against domestic defendant, a non-signatory to the arbitration agreement, because plaintiff alleged conduct that was interdependent and concerted with signatory foreign defendant. Court also held that arbitration clauses are forum or venue selection clauses and application of equitable estoppel was thus not precluded by Louisiana law.
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Hoeg v. Samsung Electronics of America, Inc., No. 23-CV-01951 (E.D. Ill. Feb. 20, 2024)02/20/2024
Court found under § 4 of the FAA, that it may grant an order to compel arbitration where a duly initiated arbitral proceeding was previously administratively closed due to the opposition’s failure to pay its fees. To hold otherwise would lead to a “never-ending game of cat-and-mouse” where the parties continue to initiate arbitration proceedings and one-party refuses to pay.
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Cameron Parish Recreation #6 v. Indian Harbor Insurance Company, No. 23-30181 (5th Cir. Feb. 19, 2024)02/19/2024
Court of Appeals vacated a discovery order and remanded to the district court to immediately grant a stay pending its decision on arbitration. Court of appeals found discovery was improper in this case, where determining if a valid arbitration agreement existed between the parties was purely a matter of law.
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Chemaly v. Lampert, No. 23-CV-24257-BB (S.D. Fla. Feb. 16, 2024)02/16/2024
Court granted in part and denied in part motions to compel arbitration pursuant to the New York Convention and to remand to state court, finding certain claims reasonably arose out of the arbitration agreement and remanding to state court the tort claims that did not fall within the scope of the arbitration agreement and did not arise under federal law.
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Port of Vancouver USA v. BNSF Railway Company, No. 3:23-CV-05560-DGE (W.D. Wash. Feb. 15, 2024)02/15/2024
Court granted defendant’s motion to dismiss and compel arbitration under the FAA as to claims that defendant was not complying with an arbitration award against it that had been confirmed by a federal court. Court reasoned that whether it could enforce the terms of the arbitration award was a “question of arbitrability” it could not resolve because the award was ambiguous.
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FGI Industries, Inc. v. Tangshan Ayers Bath Equipment Co., Ltd., No. 14-CV-00188-HDV-RAO (C.D. Cal. Feb. 13, 2024)02/13/2024
Court denied defendant’s motion to compel arbitration finding defendant waived that right by actively seeking to litigate the underlying merits of the case, including filing five motions to dismiss and multiple other procedural and substantive motions over the past twelve years.
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Carriage Court Condominiums Owners Association v. Renaissance Re, No. 23-CV-05544-LMA-MBN (E.D. La. Feb. 7, 2024)02/07/2024
Court granted defendants’ motion to compel arbitration finding the insurance policy included a valid arbitration agreement enforceable pursuant to the New York Convention and the FAA. Plaintiff failed to file a timely opposition.
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Cedar Ridge, LLC v. Certain Underwriters at Lloyd’s London, No. 23-CV-07350-SSV-JVM (E.D. La. Feb. 7, 2024)02/07/2024
Court granted defendants’ motion to compel arbitration and stay the proceedings finding arbitration is mandated under the plaintiff’s insurance policy and the dispute is governed by the New York Convention. Plaintiff did not oppose the motion.
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First United Methodist Church of Houma v. Underwriters at Lloyds of London, No. 23-CV-00610-JTM-JVM (E.D. La. Feb. 7, 2024)02/07/2024
Court granted defendants’ motion to compel arbitration finding the plaintiff’s insurance policy included a valid and enforceable arbitration clause. Court rejected plaintiff’s argument that defendants had waived their right to arbitration finding that defendants did not evince a desire to resolve the dispute through litigation rather than arbitration by admitting venue and jurisdiction were proper in their answer, raising affirmative defenses but not the issue of arbitration, conducting discovery and providing initial disclosures, participating in mediation, and the passage of significant time since plaintiff filed its petition in state court.
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Parish of Lafourche v. Indian Harbor Insurance Company, No. 23-CV-03472-SM-MBN, Dkt. No. 33 (E.D. La. Feb. 2, 2024)02/02/2024
Court denied plaintiff’s motion to remand to state court finding abstention was inappropriate, namely, because the cause of action arose under federal law under the New York Convention and FAA, and the dispute did not involve vital state interests.
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Parish of Lafourche v. Indian Harbor Insurance Company, No. 23-CV-03472-SM-MBN, Dkt. No. 34 (E.D. La. Feb. 2, 2024)02/02/2024
Court granted defendants’ motion to compel arbitration and stay proceedings finding the service-of-suit clause did not constitute a waiver of defendants’ right to compel arbitration. Instead, the clause complemented the arbitration agreement by establishing a forum where the parties may enforce an arbitration award.
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Dryades YMCA v. Certain Underwriters at Lloyds, London, No. 23-CV-03411-JTN-MBN (E.D. La. Jan. 31, 2024)01/31/2024
Court granted defendants’ motion to compel arbitration and stay proceedings finding that Louisiana state law does not prevent the enforcement of arbitration clauses in insurance contracts as to foreign insurers. Court found that the New York Convention superseded the Louisiana state law seeking to supersede federal laws regulating the business of insurance.
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Regal Games, LLC v. SellerX Eight GMBH, No. 1:22-CV-07455-ER (S.D.N.Y. Jan. 25, 2024)01/25/2024
Court granted defendant’s motion to compel arbitration pursuant to the FAA, finding that the parties formed a valid agreement to arbitrate even when the underlying agreement did not expressly contain the words arbitration or arbitrator and where the arbitrator was a non-legal expert. Court stayed the proceedings pending the outcome of the arbitration.