Benihana, Inc. v. Benihana of Tokyo, LLC
In the context of a dispute surrounding a breach of a trademark
license agreement that provided for arbitration of certain
disputes, the U.S. Court of Appeals for the Second Circuit
concluded that it was inappropriate for a district court to use its
injunction in aid of arbitration jurisdiction to issue an
injunction that went to issues already properly before the
arbitration panel. Benihana, Inc. v. Benihana of Tokyo,
LLC, Case No. 14-841, (2d Cir., Apr. 28, 2015) (Lynch,
J.) Rather, the district court's aid of arbitration
jurisdiction only extends to injunctions limited to maintaining the
status quo between the parties.
The dispute arises out of a 1994 agreement between plaintiff
Benihana America and defendant Benihana of Tokyo—two
restaurant chains operating under the Benihana brand. Under the
agreement, plaintiff received rights to use the Benihana trademarks
and to operate Benihana restaurants in certain