Moritz produced a series of Fast and Furious films for Universal.  In connection with those films, Moritz entered into contracts with Universal which contained arbitration clauses requiring arbitration of disputes arising out of or related to those agreements.  Some of the early films’ arbitration clauses delegated arbitrability issues to the arbitrator by choosing JAMS rules.  But later ones did not.  Moritz sued Universal after it did not hire him to work on an offshoot of the Fast and Furious films, known as the Hobbs & Shaw project.  This decision holds that Universal’s motion to compel arbitration was properly denied because the dispute about the Hobbs & Shaw film did not arise out of or relate to any of the contracts for the Fast and Furious films.  The arbitration clauses in those agreements did not require arbitration of any dispute between the parties, just those that arose from or related to the Fast and Furious agreements.  A clause also requiring arbitration of any dispute arising from the arbitration agreement itself did not require arbitration of all other disputes. Henry Schein, Inc. v. Archer & White Sales, Inc. (2019) 139 S.Ct. 524 does not support Universal’s argument.  It simply did away with the “wholly groundless” exception to the rule requiring courts to compel arbitration when arbitrability issues are delegated to the arbitrator, but it didn’t require arbitration of disputes unrelated to the contract in which the provision appears.