Titan Marine, LLC v. Cape Flattery Limited

Issue: (1) Whether the general rule that a contract must be interpreted to fulfill the parties intentions applies with respect to an arbitration agreement when discerning whether the parties intended that foreign law should govern the threshold question whether the dispute is subject to arbitration; and (2) when parties agree to arbitrate "any disputes arising under this Agreement," whether that restricts arbitration to only those disputes about the "interpretation and performance" of a contract, or it also includes disputes that would not have arisen but for their contract.