Late last month, the Second Circuit Court of Appeals summarily affirmed denial of a petition to vacate an arbitration award where a party was arguing that the arbitrator was biased. The case involved a dispute between an Israeli medical device company and a New York-based investment company and whether the medical device company owed a fee when it located an investor. The investment company argued that “the Arbitrator’s procedural rulings and fee award in [the medical device company]’s favor, along with her professional affiliations, evince[d] partiality.” The investment company attempted to point to the facts that (i) the arbitrator struck six of its ten document requests and refused to grant it an extension of time to engage an expert witness and (ii) the arbitrator came from the International Chamber of Commerce, where two attorneys of the medical device company were affiliated, neither of which the trial court accepted as bases for vacating the arbitration award. The Second Circuit entered an order summarily affirming. Landmark Ventures, Inc. v. InSightec, Ltd., No. 14-4599-cv (2d Cir. Oct. 30, 2015).