Narrative Opinion Summary
The court addressed a dispute between Immersion Corporation and Sony regarding an arbitral award under the New York Convention, focusing on whether Sony's DualShock® 4 controllers were 'Royalty Bearing Products' under a 2007 settlement agreement. Immersion sought to confirm the arbitral award, while Sony sought vacatur, citing public policy violations and the exclusion of key evidence. The court confirmed the award, rejecting Sony's public policy claims, which alleged that the award improperly excluded invalidity defenses and violated U.S. moral and justice standards. The court emphasized that under the New York Convention and FAA, awards should be enforced unless specific exceptions apply, and found Sony's arguments insufficient. Additionally, the court examined Sony's claims of manifest disregard of the law, concluding that the arbitrator did not flagrantly ignore legal standards. The arbitrator's authority to interpret the agreement was upheld, particularly in determining non-arbitral issues. The court also found no misconduct in the arbitrator's handling of evidence, affirming the award's confirmation. While Immersion's request for attorney's fees was denied, the court provided an opportunity for sealing the order, pending confidentiality motions.
Legal Issues Addressed
Confirmation of Arbitral Awards under the New York Conventionsubscribe to see similar legal issues
Application: The court confirmed Immersion Corporation's arbitral award against Sony, denying vacatur on the grounds of public policy and failure to consider evidence.
Reasoning: The court grants Immersion Corporation's petition to confirm an arbitral award against Sony Computer Entertainment America LLC and Sony Computer Entertainment Inc. under the New York Convention, denying Sony's request to vacate the award.
Exclusion of Evidence under 9 U.S.C. § 10(a)(3)subscribe to see similar legal issues
Application: The court found that the arbitrator's decision not to weigh certain evidence did not constitute misconduct warranting vacatur.
Reasoning: The court determined the arbitrator's decision not to prioritize this evidence did not constitute misconduct.
Judicial Review and Arbitrator's Authoritysubscribe to see similar legal issues
Application: The court deferred to the arbitrator's interpretation of the 2007 agreement, emphasizing that misinterpretations do not invalidate the award.
Reasoning: The court emphasizes that it must defer to the arbitrator's decisions on arbitrability when the matter is submitted to arbitration, supported by precedent including First Options of Chicago, Inc. v. Kaplan.
Manifest Disregard of the Law under the FAAsubscribe to see similar legal issues
Application: The court found no manifest disregard of the law by the arbitrator, as the arbitrator's interpretation did not flagrantly ignore the applicable legal standards.
Reasoning: Despite Sony's claims that the arbitrator's findings were inconsistent with Japanese law, the court cannot vacate the award based on perceived misunderstandings of the law, as manifest disregard requires more than mere errors.
Public Policy Defense under the New York Conventionsubscribe to see similar legal issues
Application: Sony's argument that the award violated public policy by excluding invalidity defenses was rejected, as the court found no contravention of fundamental U.S. principles.
Reasoning: Sony does not dispute that the public policy defense under Article V(2)(b) of the New York Convention is applicable only when confirming an arbitration award would contravene the forum state's fundamental principles of morality and justice.
Scope of Arbitration and Exclusion of Issuessubscribe to see similar legal issues
Application: The arbitrator determined that invalidity defenses were not arbitrable under the 2007 agreement, and the court upheld this decision.
Reasoning: The arbitrator, in Order No. 3, reviewed specific sections of the 2007 agreement and determined that invalidity and unenforceability were not arbitrable issues.