East Coast Karate Studios, Inc. v. Lifestyle Martial Arts, LLC

The issue in this appeal is whether a mandatory forum selection clause contained in a non-compete agreement may be applied to non-signatory parties who are alleged to have interfered with that agreement. We conclude that the mandatory forum selection clause applies to the non-signatories here because: (1) there exists a close relationship between the non-signatories and the signatory who is the subject of the agreement; (2) the non-signatories’ interests are derivative of the signatory’s interests; and (3) the claims involving the non-signatories arise directly out of the agreement.

The facts…