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Terk Technologies Corp. v. Dockery

Citations: 86 F. Supp. 2d 706; 2000 U.S. Dist. LEXIS 2232; 2000 WL 246416Docket: 2:97-cv-74812

Court: District Court, E.D. Michigan; February 2, 2000; Federal District Court

Narrative Opinion Summary

In this case, Terk Technologies Corporation initiated a legal proceeding against Devan Dockery and Windmaster Manufacturing Co. for design patent infringement, leading to claims of patent misuse by the defendants. The dispute was directed to binding arbitration, resulting in an award of $6,758,433.00 for Terk. Subsequently, Terk sought judgment on the award and a preliminary injunction to freeze the defendants' assets. The defendants challenged the arbitration outcome, citing refusal to hear evidence, fraud, and manifest disregard of the law as grounds for vacatur under the Federal Arbitration Act. The court found no abuse of discretion by the arbitrators and upheld the award, dismissing the fraud allegations due to the absence of evidence being presented at arbitration. The request for a preliminary injunction was denied as moot, with no irreparable harm demonstrated. Ultimately, the court granted Terk's motion for judgment, emphasizing the strong judicial policy favoring arbitration award confirmation.

Legal Issues Addressed

Arbitration Award Confirmation Under Federal Arbitration Act

Application: The court confirmed the arbitration award in favor of the plaintiff, as the defendants failed to meet the burden of proving any of the four grounds required to vacate an award under the Federal Arbitration Act.

Reasoning: The burden of proof lies heavily on the party seeking vacatur, as there is a strong policy favoring the confirmation of arbitration awards.

Fraud as a Ground for Vacating Arbitration Awards

Application: Defendants' fraud claim, based on alleged perjury, was rejected since the pertinent testimony was not presented to the arbitrators, thus failing to meet the statutory requirements for vacating the award.

Reasoning: Defense counsel acknowledged that Bihm's deposition was not presented to the arbitrators, negating the claim that the award was procured by fraud under 9 U.S.C. 10(a)(1).

Manifest Disregard of Law in Arbitration

Application: Defendants' assertion that arbitrators exhibited manifest disregard of the law was dismissed, as they could not demonstrate a clear violation of legal principles.

Reasoning: However, the standard for manifest disregard is strict, requiring a clear violation of established legal principles, which the defendants failed to demonstrate.

Preliminary Injunction Requirements

Application: The plaintiff's request for a preliminary injunction was denied as moot, given the court's ruling on the motion for judgment, and the absence of demonstrated irreparable harm.

Reasoning: The Court denies the plaintiff's motion for a preliminary injunction without prejudice.

Refusal to Hear Evidence in Arbitration

Application: The defendants' claim that the arbitrators refused to hear evidence was rejected, as the court found no abuse of discretion in the arbitrators' evidentiary rulings.

Reasoning: The arbitrators deemed the Larsen case irrelevant, and evidentiary decisions are typically afforded high deference, with appeals only succeeding on a demonstration of abuse of discretion.