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In North America

Second Circuit affirms arbitration award while confirming continuing applicability of manifest disregard of law

by 5 Mins Read

Seneca Nation of Indians v. State of New York, No. 19-4022 (2d Cir. Feb. 22, 2021) [click for opinion] On August 18, 2002, the Seneca Nation of Indians (the “Nation”) entered into a Compact with the State of New York for gambling activities in the Western District of New York. The Compact was for an initial 14-year term with an automatic renewal period of 7 years. It required the Nation to pay New York a percentage…

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In North America

District court grants motion to compel arbitration, finding that parties had delegated questions of unconscionability to the arbitrator

by 2 Mins Read

Zeevi v. Citibank, N.A., No. 2:19-cv-02206-GMN-BNW (D. Nev. Feb. 16, 2021) [click for opinion] In March 2019, Plaintiff Daniel Zeevi opened a bank account with a Las Vegas, Nevada branch of Defendant Citibank, N.A. (“Citibank”). In doing so, Zeevi restricted any potential text notifications related to his transaction history to those transactions of $101.00 or greater. Zeevi claimed that Citibank nevertheless sent him text messages related to transactions less than or equal to $100.00, in violation…

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In Arbitration Procedure

US Court holds that service providing actual notice of arbitration-related court proceeding is sufficient under the FAA

by 3 Mins Read

TVL Int’l, LLC v. Zheijiang Shenghui Lighting Co., No. 3:19-CV-00393-RJC-DCK (W.D.N.C. Feb. 2, 2021) [click for opinion] In 2014, Plaintiff TVL International, LLC (“TVL”), a Delaware corporation, and Defendants Zheijiang Shenghui Lighting Co., Ltd. (“Zheijiang”), a Chinese LED light bulb manufacturer, and SengLED USA, Inc. (“SengLED”), Zheijiang’s U.S. subsidiary, executed a non-disclosure agreement relating to their efforts to jointly develop a “battery back-up LED light bulb”. By 2015, the parties had stopped working together and eventually…

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In North America

California appellate court overturns arbitration award that violated Plaintiff’s statutory right to work

by and 4 Mins Read

Brown v. TGS Management Co., 57 Cal. App. 5th 303 (2020) [click for opinion] TGS Management Co., Ltd. (“TGS”) was a private limited liability company that engaged in a highly computerized form of equities trading known as statistical arbitrage. Richard Hale Brown was an employee of TGS, who signed an employment agreement containing confidentiality and non-compete provisions when he commenced work there in 2005. In February 2016, TGS terminated Brown’s employment without cause, effective March…

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