Broadbase Ventures Ltd v American Arbitration Association Inc - United States District Court Southern District of New York Case No 1-26-cv-09555 - Complaint - Mass Arbitration Challenge - (Incl Process Conference Order No 2 - Process Order No 9 AAA Case Number 01-26-0000-7411) - 2 November 2026

Country
Year

2026

Summary

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PRAYER FOR RELIEF

WHEREFORE, Plaintiffs respectfully request that the Court enter judgment in their favor and against AAA, and grant the following relief:

(A) A declaration that Defendant, and all persons or entities acting in concert with Defendant, cannot exercise jurisdiction over Plaintiffs in the Mass Arbitration nor do they have jurisdiction to decide that Plaintiffs are alter egos of the Signatory Respondents in the Mass Arbitration;

(B) A temporary restraining order, on an emergency basis, pursuant to Plaintiff's separate motion for a temporary restraining order, enjoining Defendant, and all persons or entities acting in concert with Defendant, from exercising jurisdiction over Plaintiffs and from finding, presumptively or otherwise, that Plaintiffs are alter egos of the Signatory Respondents in the Mass Arbitration;

(C) A preliminary injunction granting the relief described in paragraph (B) above pending final judgment in this action, pursuant to a motion for a preliminary injunction filed separately;

(D) An order directing Defendant to reassign the Mass Arbitration to a new process arbitrator in order to avoid any further improper exercise of Defendant's jurisdictional authority;

(E) An award of Plaintiff's costs and expenses, including reasonable attorneys' fees, to the extent permitted; and

(F) Such other further relief as the Court deems just and proper.

Dated: November 2, 2026

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