Introduction

It is fair to say that the approach of the courts of common law jurisdictions, such as Ireland and England, is generally to adopt a wide interpretation of the scope of arbitrable issues in favor of arbitration.[1] This contrasts with the unique position adopted by the Second Circuit of the United States in In Re Kinoshita [2] in which it afforded a very narrow reading of the relevant arbitration clause, finding that an arbitration clause providing for arbitration of " any dispute or difference... aris[ing] under " the contract containing the clause was not sufficiently ...