BIRMINGHAM ASSOCIATES LTD. v. Abbott Laboratories
Birmingham Associates Ltd. sued Abbott Laboratories for breach of a Keep Well Agreement after Abbott terminated the development of a stent product in which Birmingham had invested. Abbott moved to compel arbitration, asserting that despite the Keep Well Agreement lacking an arbitration clause, the dispute was intimately tied to a Funding Agreement between Birmingham and Abbott's subsidiary, ALVE, which included a broad arbitration clause. The court granted Abbott's motion, applying the equitable estoppel doctrine due to the close relationship between Abbott and ALVE and the intertwined nature of the agreements, ruling that Birmingham could not rely on the agreements for its claims while simultaneously avoiding their arbitration provisions. The action was dismissed, compelling the parties to resolve the dispute through arbitration.