such as “arising out of or in relation to” must be meaningful. See Mediterranean Enterprises, 708 F.2d at 1464. For example, in construing the phrase “arising under” as narrow, the Ninth Circuit stated that “[t]he standard phrase suggested in the U.S.-Korean Commercial Arbitration Agreement contains the phrase “out of or in relation to or in connection with the contract, or for the breach thereof.” Id. Because the agreement before that court excluded much of that language, and referred only to “any disputes arising hereunder,” the court reasoned that “[w]e have no difficulty finding that ‘arising hereunder’ is intended to cover a much narrower scope of disputes, i.e., only those relating to interpretation and performance of the contract.” Id.; see also Kinoshita, 287 F.2d at 953 (<HOLDING>). In contrast, the majority of federal courts
holding that an arbitration clause was narrow when it called for arbitration only of disputes relating to certain payments made under the lease holding that the parties choice to require arbitration for disputes which arise under a contract when the standard language was arising out of or relating to demonstrated that the parties intended the agreement to be narrow holding that the plain language of the warranty reveals no clear intent by the parties to refer to arbitration disputes over contract duration holding that even if the parties had formed a contract under  2207l the arbitration clause materially altered the contract and therefore did not become part of the parties agreement holding that faa was inapplicable where parties involved in action are not parties to an arbitration agreement under which issues are referable to arbitration