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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION

Mark R. Figueiredo, Esq. (SBN 178850)

Ethan G. Solove, Esq. (SBN 308026)

Jaclyn M. Ford, Esq. (SBN 272641)

STRUCTURE LAW GROUP, LLP

1754 Technology Drive, Suite 135

San Jose, California 95110

Telephone: (408) 441-7500

Facsimile: (408) 441-7501 

Attorneys for Defendants 

INDYZEN, INC. and PRAVEEN NARRA KUMAR

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

PARKRIDGE LIMITED, a Hong Kong 

corporation, by Mabel Mak, and MABEL 

MAK, an individual,

Plaintiffs,

v.

INDYZEN, INC., a California corporation, 

and PRAVEEN NARRA KUMAR, an 

individual,

Defendants.

 

CASE NO. 16-CV-07387-KAW

REPLY IN SUPPORT OF DEFENDANT’S 

PETITION FOR ORDER TO COMPEL 

ARBITRATION AND MOTION TO STAY 

ACTION PENDING ARBITRATION

Date: April 20, 2017

Time: 11:00 AM

Dept.: TBD

Judge: Hon. Kandis A. Westmore

I. INTRODUCTION

The most important thing said in Plaintiffs’ opposition is what is not said. 

Plaintiffs do not mention Count IV (Breach of Contract) anywhere in their brief. Their silence

concedes that Count IV should be sent to arbitration.

The Court should send the entire lawsuit to arbitration at the very least because every 

cause of action depends on or is inextricably intertwined with Count IV. If an arbitrator rules that 

Count IV fails because there was no breach of the Morfit Agreement, then none of Plaintiffs’ 

other causes of action can succeed. Further, for the sake of argument, even if the other claims do 

not all completely depend on the outcome of Count IV, the arbitrator is still likely to make 

findings of facts and other determinations in ruling on Count IV that will seriously implicate all 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

of the other claims, since they all are bound up in the Morfit Agreement. Thus, the entire case 

should be sent to arbitration to promote judicial efficiency, to avoid duplicating the arbitrator’s 

efforts, and to avoid the risk of contradictory rulings. However, if the Court is inclined to 

withhold any causes of action from arbitration, it should stay the litigation pending the outcome 

of the arbitration. In that event, the parties will have a final ruling on the causes of action that are 

submitted to arbitration, which will inform the remainder of the case. 

In their opposition, Plaintiffs argue that individuals Praveen Narra Kumar (“Narra”) and 

Mabel Mak (“Mak”) should not be ordered to arbitration because they did not sign the Morfit 

Agreement. These arguments are wrong. First of all, Narra did sign the Morfit Agreement as the 

CEO of Indyzen, Inc. (“Indyzen”), a fact that undercuts Plaintiffs’ entire argument against 

Narra’s ability to compel arbitration. Even if this were not the case, however, Narra should be 

allowed to compel arbitration, because he would have been sued by Plaintiffs solely in his 

capacity as Parkridge Limited‘s (“Parkridge”) CTO. Thus, agency principles and the doctrine of 

equitable estoppel would allow Narra to compel arbitration. Mak should also be sent to 

arbitration under equitable estoppel because she seeks the benefits of the Morfit Agreement by 

suing under it while trying to avoid its obligation to arbitrate. Further, both individuals should 

also be sent to arbitration in the interest of judicial efficiency. Thus, the Court should order all of 

the parties and the entire case to arbitration.

Finally, Plaintiffs argue that some of their causes of action deal not with the Morfit 

Agreement directly, but rather with Defendants’ inducement of Plaintiffs to sign it. As a result, 

they say that those causes of action should not be governed by the Morfit Agreement’s arbitration 

clause. This argument is wrong on multiple levels. Not only is Plaintiffs’ case law off base, but 

the entire lawsuit, including those parts of it that Plaintiffs say deal with inducement, are 

inextricably bound up in the Morfit Agreement such that its arbitration clause should govern 

everything.

\\\

\\\

\\\

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

II. ANALYSIS

A. Plaintiffs Concede That Count IV (Breach of Contract) Should Be Sent To 

Arbitration.

Plaintiffs do not mention Count IV (Breach of Contract) anywhere in their 13-page 

opposition. As discussed in Defendants’ moving papers, Count IV arises out of the Morfit 

Agreement because it alleges that Indyzen “breached the [Morfit] Agreement.” (Pet. at page 6, 

lines 8-9.) With their silence, Plaintiffs concede this point. As such, there is no doubt that the 

Court should send Count IV to arbitration. 

B. All Other Counts Are Inextricably Related To Count IV (Breach of Contract)

So They Should All Be Sent To Arbitration. If Any Are Not, The Lawsuit

Should Be Stayed Pending The Outcome Of Arbitration.

As discussed above in Section II.A, Plaintiffs concede that Count IV should be sent to 

arbitration. As such, every other cause of action should be sent with it. 

Count IV is the heart of this lawsuit. It alleges that Defendants breached the Morfit 

Agreement. Every other cause of action depends on the outcome of Count IV, or at the very least 

is bound up in the same facts such that a ruling on Count IV would implicate rulings on the other 

claims. (See Mot. at page 5, line 3 to page 7, line 10.) Plaintiffs essentially argue that Defendants 

got Plaintiffs involved in the Morfit Agreement when Defendants never intended to honor it, and 

that Defendants have wrongfully benefited from their breach of the Morfit Agreement. If an 

arbitrator rules that there has never been a breach of the Morfit Agreement, then all of the other 

causes of action will fail in turn. Further, for the sake of argument, even if there is not a direct 

dependency between Count IV and the other counts, an arbitrator is likely to make rulings and 

findings of fact in considering Count IV that will implicate all of the other counts. As such, all of 

the causes of action are inextricably bound up in Count IV, so they all should be sent to 

arbitration along with it.

Case law on judicial efficiency also favors this. (See, e.g., Alexander v. Gardner-Denver 

Co. (1974) 415 U.S. 36, 58 (“Indeed, it is the informality of arbitral procedure that enables it to 

function as an efficient, inexpensive, and expeditious means for dispute resolution.”). Plaintiffs’ 

arguments against arbitration are built on an incorrect focus on Tracer Research Corp. v. Nat’l 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

Envtl. Servs. Co (9th Cir. 1994) 42 F.3d 1292, which dealt with a clause that had different 

language than the one here, as discussed at length in Section II(D) below. Further, Plaintiffs’

citation to Moses H. Cone Mem’l Hosp. v. Mercury Constr. Corp. (1983) 460 U.S. 1, 20 to make 

the assertion that “[t]he Federal Arbitration Act ‘requires piecemeal resolution when necessary to 

give effect to an arbitration agreement” is taken out of context. (Opp. at page 5, lines 12-14.) 

This case is distinguishable because there, the Court actually acknowledged the “danger of 

piecemeal litigation” immediately before concluding that they were using it in a rare situation. 

(Moses, supra, 19-20.)

In sum, the Court should send the entire case to arbitration along with Count IV. 

Plaintiffs have conceded that Count IV should be sent to arbitration. Judicial efficiency favors 

having this entire case resolved in one fell swoop along with it.

However, if the Court is inclined to withhold any cause of action from arbitration, it 

should stay the litigation pending the outcome of the arbitration. It is not the case that “little if 

anything would be saved by awaiting the outcome of arbitration” as alleged by Plaintiffs. (Opp. 

at page 13, pages 3-4.) Rather, judicial efficiency strongly favors a stay, because the outcome of 

all of the causes of action will depend on the outcome of Count IV, or at the very least, the 

arbitrator will make rulings and determine findings of fact in ruling on Count IV that will 

implicate all of the other causes of action. (See U.S. for Use & Benefit of Newton v. Neumann 

Caribbean Int’l Ltd. (1985) 750 F.2d 1422, 1426-27 (stressing the importance of staying a case 

pending the outcome of arbitration to avoid “duplication of effort” and stressing the common 

sense of avoiding two tracks.) Plaintiffs’ citation to United Commc’ns Hub, Inc. v. Qwest 

Commc’ns (9th Cir. 2002) 46 F. App’x 412 to argue against the stay is misplaced, since that case 

actually says that putting in place a stay like this one is only “appropriate where the arbitrable 

claims predominate, or where the nonarbitrable claims will depend on the arbitrator’s decision.” 

As discussed above, this is exactly our situation. A stay will ensure that the Court does not 

duplicate the arbitrator’s efforts, and will also avoid the risk of contradictory rulings. It just does 

not make sense to have this case proceed at the same time on two different tracks. Thus, if the 

Court does not send the entire case to arbitration, it should stay the remainder of the case pending 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

the arbitration’s outcome.

C. Every Party To This Lawsuit Should Be Ordered To Arbitration, Regardless 

Of Whether Or Not They Signed The Morfit Agreement.

1. Contrary To Plaintiffs’ Assertions, Narra Did Sign The Morfit 

Agreement. But Even If He Had Not, Agency Principles And 

Equitable Estoppel Allow Him To Compel Arbitration.

In their opposition, Plaintiffs argue that Narra should not be ordered to arbitration, 

because they say that he did not sign the Morfit Agreement. This assertion is wrong on its face. 

Narra did sign the Morfit Agreement as Indyzen’s CEO. (Morfit Agreement, Page 8, attached as 

Exhibit B to Plaintiffs’ Compl.) This fact cuts off at the knees Plaintiffs’ arguments that Narra 

cannot compel arbitration. 

Further, even if Narra had not signed the Morfit Agreement—which he did—Plaintiffs’ 

argument does not take into account that fact that Narra would only be involved in this lawsuit 

because Plaintiffs would have sued him solely in his role with Parkridge, which did sign the 

Morfit Agreement. Plaintiffs acknowledge this in their opposition only one page after arguing 

that Narra should not be allowed to arbitrate, alleging that “[h]ere, Narra’s wrongdoings stem 

from his roles and duties as Parkridge’s CTO.” (Opp. at page 7, line 16.) Agency principles 

would allow Narra to compel arbitration because Plaintiffs would have sued him solely in his 

capacity as Parkridge’s CTO. Agency principles allow a non-signor to compel arbitration when 

plaintiffs have alleged, like here, that “the defendant acted as an agent of a party to an arbitration 

agreement.” (Thomas v. Westlake (2012) 204 Cal. App 4th 605, 614.) The doctrine of equitable 

estoppel also would allow Narra to compel arbitration, because he would only be involved in this 

case as a result of his close relationship with signor Parkridge and because the alleged claims are 

inextricably intertwined with the underlying contractual obligations. (See Mundi, supra, 555 F.3d 

1042.) 

Further, all of the cases used by Plaintiffs to try to argue that Narra cannot compel 

arbitration are wrong. In all of their cases, the non-signor who brought the motion to compel was 

completely unrelated from the contract containing the arbitration clause. Here, however, Narra is 

in fact a signor, and is also deeply involved in all of Plaintiffs’ allegations, which all involve the 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

Morfit Agreement. 

This is not a case where Narra is being sued as an individual because of things he did out 

in the world on his own. Rather, Narra is a signor to the Morfit Agreement, contrary to Plaintiffs’ 

assertions. But even if he were not a signor to the Morfit Agreement, Narra would only have 

been sued because of allegations that solely relate to his role as Parkridge’s CTO. As a result, no 

matter how one looks at it, Narra should be allowed to compel arbitration. 

2. Mak Should Be Required To Arbitrate The Case Under The Doctrine 

Of Equitable Estoppel.

In their moving papers, Defendants argued that the doctrine of equitable estoppel requires 

Mak to be ordered to arbitration, because she has sought the benefit of the Morfit Agreement by 

bringing her entire lawsuit under it. In their opposition, Plaintiffs have not offered any argument 

against Defendants equitable estoppel argument. All that they have done is unsuccessfully try to 

distinguish Defendants’ case law.

In reality, Mak should be ordered to arbitration because she has sought the benefits of the 

Morfit Agreement while trying to avoid its obligations. All of Plaintiffs’ attempts to distinguish 

Defendants’ case law fail. It is not the case that Mundi v. Union Sec. Life Ins. Co. (2009) 555 

F.3d 1042 or Murphy v. DirecTV, Inc. (2013) 724 F.3d 1218 “favor” Plaintiffs. In fact, the court 

in Mundi specifically said that “a nonsignatory may be held to an arbitration clause where the 

nonsignatory knowingly exploits the agreement containing the arbitration clause despite having 

never signed the agreement.” (Mundi, supra, at 1046.) This is exactly our situation. With 

regard to Murphy, this case was only offered by Defendants as general law on equitable estoppel. 

The fact of the matter is that Mak has sued Defendants as an owner of Parkridge1and 

brought each of her causes of action along with Parkridge seeking the benefit of a contract that 

Parkridge entered into for her gain. Thus, the doctrine of equitable estoppel requires that Mak 

arbitrate her claims. 

///

///

 

1 Plaintiffs’ opposition states that Randy Dobson is the owner of Parkridge. (Opp. at page 2, line 24.) But this Court 

need not resolve this factual discrepancy now. 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

3. In Addition To The Reasons Set Forth In The Previous Two Sections, 

The Court Should Also Order Mak And Narra To Arbitration For 

Judicial Efficiency.

As discussed above in Sections II.C(1-2), Mak and Narra should be sent to arbitration. 

Narra is a signor of the Morfit Agreement and is clearly allowed to compel arbitration under it. 

Further, even if this were not the case, the Court should still send them both to arbitration under 

agency principles and equitable estoppel. On top of all of this, the Court should order Mak and 

Narra to arbitration for all the reasons of judicial efficiency discussed in the sections above. 

D. The Remainder Of Plaintiffs’ Arguments Fail. 

The remainder of Plaintiffs’ opposition focuses primarily on assertions that some of the 

events alleged in Plaintiffs’ lawsuit happened before the Morfit Agreement was signed, when

Defendants allegedly induced Plaintiffs into signing up for an allegedly bad contract. However, 

these arguments fail for several reasons. To begin with, the case law cited by Plaintiffs in support 

of this argument is wrong. Plaintiffs try to rely on Britton v. Co-op Banking Group (9th Cir. 

1993) 4 F.3d 742 to argue that the claims in their complaint that deal with inducement to contract 

fall outside of the scope of the arbitration clause. (Opp. at page 9, lines 4-6.) However, as 

acknowledged by Plaintiffs, the Court in Britton limited its analysis to acts that happened after 

(i.e. “subsequent to”) the Agreement was entered into, not before as would be relevant for 

Plaintiffs’ inducement claims. (Britton, supra at 748.) Further, Britton was analyzing a situation 

in which the parties’ dispute was completely unrelated to the agreement with the arbitration 

provision. Here, as discussed throughout this reply, Defendants’ moving papers, and below, 

Plaintiffs’ inducement claims are part and parcel to the Morfit Agreement, so Britton is not 

relevant. 

The reality is that this entire case is about the Morfit Agreement. The cases that Plaintiffs 

use in their attempts to argue the contrary are all wrong. The respective courts in each case only 

ruled against arbitration because the agreements containing the arbitration clauses were irrelevant 

to the causes of action. (See Murphy v. DirecTV, Inc. (9th Cir. 2013) 724 F.3d 1218, 1230 

(finding that the agreement with the arbitration clause was “factually irrelevant to” plaintiffs’

claims); Palmer Ventures LLC v. Deustche Bank AG (5th Cir. 2007) 254 Fed. Appx. 426, 432 (an 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

out-of-circuit case finding that the arbitration document was not “a part of the Plaintiffs’ causes of 

action.”); Goldman v. KPMG LLP (2009) 173 Cal. App. 4th 209, 218 (a state court case finding 

that the claims were “unrelated” to the agreements with the arbitration clauses.) 

Plaintiffs are wrong to say that the current case is like any of these other cases, when here

the heart of the case is the Morfit Agreement. Again, the term “Morfit” appears in the complaint 

over 80 times. Contrary to Plaintiffs’ assertions, every Count references the Morfit Agreement, 

and thus, none is viable without reference to or interpretation of it. One only needs to look at the 

Prayer in the Plaintiffs’ complaint to see how central the Morfit Agreement is to the case, as 

Plaintiffs only request damages that allegedly stem from breach of the Morfit Agreement, 

including an injunction to require Defendants to give Plaintiffs the Morfit App and attorneys fees 

as “authorized by the [Morfit] Agreement.” (Compl. at 27, lines 1-2.) Moreover, Parkridge’s 

references to “Intellectual Property” as stated in Requests for Relief #3 and #4, and “Attorneys’ 

Fees” as stated in Request #5, are only understandable when defined by interpreting the Morfit 

Agreement. Thus, despite Plaintiffs’ efforts to try to split hairs about timing, the reality is that 

this entire case is about the Morfit Agreement. 

Second, the language of the Morfit Agreement’s arbitration clause is very broad. It states 

that “any dispute or disagreement arising between” the parties should be sent to arbitration. 

(Compl., Exhibit B, Page 6, ¶ 11 (emphasis added).) It does not limit arbitration to only the

disputes related to the Morfit Agreement. Nonetheless, despite this broad language, Defendants 

are not even arguing that this arbitration clause should bind Plaintiffs to something unrelated to 

the Morfit Agreement. Rather, Defendants seek to hold Plaintiffs to the dispute resolution 

method which was agreed upon when the Morfit Agreement was signed. 

Plaintiffs present an argument that parses out the phrase “relate to or arise out of,” and that 

relies on Tracer v. Research Corp v. Nat’l Environmental Services Co. (9th Cir. 1994) 42 F.3d 

1292, 1295 while trying to distinguish Defendants’ use of Simula, Inc. v. Autoliv, Inc. (9th Cir. 

1999) 175 F.3d 716. (Opp. at page 8, lines 4-28 to page 9, 1-18.) Plaintiffs reliance on Tracer is 

wrong, because the arbitration clause discussed in that case is different than the one at bar. There, 

the operative language was “arising out of this Agreement,” whereas here, the arbitration clause 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

uses “arising between [Indyzen] and [Parkridge]. (compare Tracer, supra, at 1295 to the Morfit 

Agreement Arbitration Clause (emphases added).) The language in this case is broader and 

encompasses claims that might arise between Parkridge and Indyzen that may or may not be 

related to the Morfit Agreement. Thus, Tracer has no bearing on this case. Further, with respect

to Simula, Inc., Defendants used that case in their moving papers to show that while Courts have 

interpreted the phrase “arising in connection with” broadly, the language “arising between” in this 

case is even broader. (compare Simula, Inc. (9th Cir. 1999) 175 F.3d 176, 721 to the Morfit 

Agreement Arbitration Clause.) This point is further backed by other case law. (See, e.g. 

Pyramid Travel, Inc. v. Sri Lankan Travel, Inc. (C.D.C.A. 2000) 2000 WL 34017119, at *5 

(characterizing an arbitration clause using the language “arising between the parties” as “even 

broader” than the “arising in connection” language from Simula or the narrower “arising out of” 

language of Tracer); Local Union No. 721 v. Needham Packing Co. (1964) 376 U.S. 247, 251; 

Amalgamated Clothing and Textile Workers Union, AFL-CIO-CLC v. Ratner Corp. (9th Cir. 

1979) 602 F.2d 1363, 1371 (Local Union No. 721 and Ratner both stand for the proposition that 

an arbitration clause covering all disputes arising between parties is very broad). 

In sum, Plaintiffs’ inducement argument does not hold water. Plaintiffs’ case law is not 

on point and the entire lawsuit is bound up with the Morfit Agreement, which provides arbitration 

as the sole means of dispute resolution. 

III. CONCLUSION

Plaintiffs concede that the heart of this case, Count IV, should be sent to arbitration. If an 

arbitrator rules that Count IV fails because there was no breach of the Morfit Agreement, then the 

remainder of the lawsuit will also fail because it all depends on Count IV succeeding, or at the 

very least, the arbitrator is likely to make rulings and findings that will seriously implicate the 

other causes of action. Judicial efficiency and avoidance of the risk of contradictory rulings also 

favor sending the entire case to arbitration. However, if the court is inclined to withhold any 

cause of action from arbitration, it should stay the litigation pending the outcome of the 

arbitration. This will ensure that the Court does not duplicate the arbitrator’s efforts and will 

prevent the risk of contradictory rulings. 

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REPLY IN SUPPORT OF DEFENDANT’S PETITION FOR ORDER TO COMPEL ARBITRATION AND 

MOTION TO STAY ACTION PENDING ARBITRATION 

For the foregoing reasons, Defendants respectfully request that the Court grant their 

Petition for Order Compelling Arbitration and concurrently filed Motion to Stay Action Pending 

Arbitration by sending the entire case to arbitration, or in the alternative, sending some of the 

claims to arbitration while staying the litigation pending the arbitration’s outcome. 

Dated: March 29, 2017 STRUCTURE LAW GROUP, LLP

By: /s/ Ethan G. Solove

Ethan G. Solove, Esq.

Attorneys for Defendants

INDYZEN, INC. and PRAVEEN NARRA 

KUMAR

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