Holding that non-signatories may be bound even when not asserting a claim on the contract if they "deliberately seek and obtain substantial benefits from the contract itself."
Holding that the fact that the party resisting arbitration could not rely for that purpose on the separate corporate existence of a number of Enron affiliates that it had referred to collectively in a prior complaint as the "Enron Group"
Holding that the nonsignatory received direct benefits, prior to litigation, from the agreement, including lower insurance rates and other maritime rights
Holding that non-signatory local affiliate, who used a trade name pursuant to an agreement that it ratified which contained an arbitration clause, was estopped from relying on its nonsignatory status to avoid arbitrating under the agreement
Opining the plaintiffs’ "have alleged a concrete injury--that they are being deprived of their contractual right to arbitrate--and that this injury is caused by [the defendants’] refusal to arbitrate under the Reinsurance Certificates’ dispute-resolution provisions."
458 F. Supp. 2d 355 (S.D. Tex. 2006) Cited 28 times
Finding that the first type of estoppel did not apply because a party to the contract containing an arbitration clause was attempting to enforce that clause against a nonparty
Concluding that question of timeliness "must be resolved by an arbitrator under [the act's] principles" where choice of law clause provided only that "the Agreement shall be governed by, and construed in accordance with, the laws and decisions of the State of New York," and "[did] not include the critical enforcement language"