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New York Court of Appeals Upholds Web-Based “Clickwrap” Agreement to Affirm Order Compelling Arbitration, Including Threshold...

In January 2021, Uber emailed millions of its users informing them that they would be prompted to agree to updated terms of use (available by hyperlinks) in order to continue using the ride-sharing service. The plaintiff, a...more

Second Circuit Rejects Enforcement of Class Waiver and Arbitration Agreement Under FAA, Finds That Provisions Impermissibly...

The plaintiff sued the trustee of his retirement plan, his former employer, and others for breach of fiduciary duties in connection with the plan’s purchase of shares of the employer’s parent company for more than fair market...more

Second Circuit Affirms Order Confirming Arbitration Award Finding No Partiality Related to Arbitrator’s (Attenuated) Personal and...

An individual appealed from an order confirming an arbitration award. The appellant argued that the district court erred in refusing to vacate the arbitration award on grounds of “evident partiality.” The appellant contended...more

Fifth Circuit Dismisses Appeal of Order Denying Motion to Reopen Case, Sever Cost-Splitting Provision, and Impose Costs of...

The underlying dispute related to a property manager’s limitation of the appellant, Jane Doe, to one pet in her apartment. Doe sued the manager for declaratory relief, injunctive relief, monetary damages, and punitive damages...more

Eleventh Circuit Holds That “Notice of a Motion to Vacate” Under FAA Cannot Be Accomplished by Email Absent Express Written...

After an arbitration resulted in an award that included more than $650,000 in attorneys’ fees, the liable party filed a motion to vacate that portion of the award in a federal district court. The attorney for that party,...more

Fourth Circuit Enforces Arbitration Agreement’s Waiver of Appellate Review

The Fourth Circuit Court of Appeals upheld the enforceability of an employment agreement’s waiver of appellate review of an arbitration award. The waiver purported to waive both judicial and appellate review of the...more

Court Applies "Summary-Judgment-Like" Approach To Uncontested Motions To Compel Arbitration And Stay Litigation

The court considered a restaurant franchisee’s motion to compel arbitration, and motion to dismiss, or, in the alternative, stay an employee’s race discrimination and retaliation lawsuit pending the completion of arbitration....more

Eleventh Circuit Affirms Denial of Imax Corp.’s Petition to Vacate Arbitration Tribunal Rulings That Included Awards of Nearly $1...

The arbitration awards involved several agreements for the sale, lease, and maintenance of Imax theater systems in South and Central America and the Caribbean. The arbitral tribunal issued a partial final award, and then...more

Third Circuit Affirms Denial of Motion to Compel Car Rental Class Action to Arbitration Based on Insufficiently Incorporated...

Seven plaintiffs filed a putative class action against a car rental company and its subsidiary for allegedly unauthorized charges incurred when the plaintiffs rented cars from the company....more

Third Circuit Addresses Interplay Between LMRA and FAA and Affirms Arbitration Award in Favor of Union Under Collective Bargaining...

The case relates to the disposition of accrued vacation time of unionized nurses after a new employer (Prospect) assumed a collective bargaining agreement. Prospect construed the collective bargaining agreement differently...more

After Reviewing the Arbitration Record, Court Enters Default Judgment Confirming Default Arbitration Award

Plaintiff Choice Hotels International Inc. filed an application to confirm arbitration award and a motion for default judgment against a fanchisee company and its owner in connection with an arbitration initiated before the...more

Ninth Circuit Affirms Order Denying Arbitration, Applying Precedent That State Law Does Not Overcome the New York Convention’s...

In a trademark dispute, Shrinivas Sugandhalaya LLP (SS LLP), an incense manufacturing company based in Mumbai, appealed the denial of its motion to compel arbitration against Balkrishna Setty and his company Shrinivas...more

Third Circuit Reverses Order Denying Arbitration, Ruling That State Law Prohibiting Arbitration Of Insurance Matters Challenged...

Applied Underwriters Captive Risk Assurance Company appealed from the denial of its motion to compel arbitration in a dispute related to a reinsurance participation contract with South Jersey Sanitation Company. The trial...more

Second Circuit Upholds Refusal To Compel Arbitration Due To Unavailable Forum, Recognizing Split In Federal Circuits

A borrower had previously entered into three payday loan agreements that contained arbitration provisions mandating that all claims be arbitrated in the National Arbitration Forum (NAF), and under the Code of Procedure of the...more

Court Considers Defenses Under Both New York Convention And The FAA In Confirming Domestic Arbitration Award Against Foreign Party

Immersion Corporation, a U.S. company, had previously entered into a settlement with Sony, a Japanese company, regarding the latter’s alleged patent infringement. Subsequently, a dispute arose surrounding whether Sony was...more

State Statute Of Limitations For Recognition Of Foreign Judgments Held Not Preempted By FAA

National Aluminum Co., Ltd. (“NALCO”) prevailed in arbitration held in India against Peak Chemical Corp. in 2005. Ultimately, the award was affirmed on appeal by an Indian court in February 2012. When earlier this year, NALCO...more

Tennessee Supreme Court Holds That State Unconscionability Law Does Not Implicate Concepcion And Is Not Preempted By FAA

The Supreme Court of Tennessee reversed the lower courts’ rulings that a non-mutual arbitration provision in an installment contract on the sale of a manufactured home was unconscionable and unenforceable. In doing so,...more

Seventh Circuit Rejects Challenge To Arbitration Award Based On “Manifest Disregard Of The Law” And Fraud

This case involved a FINRA arbitration held to resolve a dispute over money allegedly owed to Ameriprise Financial Services by a former financial adviser. The financial adviser appealed the district court’s confirmation of...more

Incorporation Of AAA Rules “Clearly And Unmistakably” Delegates Questions Of Arbitrability To Arbitrator

In a putative class action for denial of employment benefits brought by security contractors against their hiring firm, Blackwater Security Consulting, the court found that the governing agreements delegated the issue of...more

Arbitration Roundup

Emilio v. Sprint Spectrum L.P., Case No. 14-732-cv (2d Cir. Nov. 12, 2014) (affirming denial of motion to vacate award; district court did not err by finding that arbitrator did not exceed powers nor manifestly disregard law...more

Under FAA, Chicago Court Refuses To Determine Whether Claims Should Be Part Of Pending New York Arbitration

A dispute involving competing actions between two competing aeroponic farming companies, FarmedHere, LLC and Just Greens, LLC (doing business as Aero Farm Systems), was simultaneously at issue in a New York arbitration, a New...more

Arbitration Denied In Class Action Where Plaintiff’s Trust Was A Party To Arbitration Agreement, But Plaintiff Was Not

In a life settlement transaction, in which a life insurance policy is sold by its owner to another for more than its cash-surrender value but less than the net death benefit, the seller contended that the broker and purchaser...more

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