On September 13, 2017, the Federal Circuit affirmed the decision of the federal district for the Northern District of California holding that equitable estoppel to compel arbitration is limited to narrow situations. Waymo LLC v. Uber Tech., Inc., et al., No. 2017-2130 (Fed. Cir. Sept. 13, 2017). Waymo alleged, among others, that defendants Uber, Ottomotto, and Otto Trucking violated trade secret laws by employing Levandowski. Defendants filed a motion to compel arbitration based on the grounds that Levandowski's employment agreements with Waymo contained arbitration clauses and that Waymo relied on these agreements to prove its claims against the defendants. Waymo denied any such reliance. In denying the motion to compel arbitration, the district court found that equitable estoppel does not apply here as Waymo didn't rely on the agreements. In affirming the district court's decision, the Federal Circuit reasoned that California precedence requires that equitable estoppel to compel arbitration be applied only when the issues of the complaint are intimately intertwined with the non-party agreement containing the arbitration clause.
Full text of the opinion is available here.
Full text of the opinion is available here.
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