Getty Images to exercise all rights and remedies available to it under copyright laws around the world.” Wu argues that the right to bring a suit for infringement is a right or remedy available under the copyright law. The Court does not agree with Wu’s interpretation of the contract. It may be that Wu will have the right to seek damages from Pearson or enjoin Pearson from further violations of his copyright, meaning he can exercise all rights and remedies against Pearson, but the clause does not say anything about the forum where Wu has the right to enforce those rights and remedies. Read in conjunction with the broad arbitration agreement, this clause does not create the sort of carve-out that Wu claims. See Robert Bosch Corp. v. ASC, Inc., 195 Fed.Appx. 503, 507 (6th Cir.2006) (<HOLDING>). II. Class Certification — Wu I Pursuant to
holding in a battle of the forms inquiry that a term reserving all rights and remedies for one party did not conflict with an arbitration provision holding civil rico and robinsonpatman act claims subject to arbitration based on an arbitration provision in salesconfirmation forms holding that the court must consider the adequacy of the inquiry into the conflict the extent of the conflict and the timeliness of the motion recognizing the conflict holding that a dispute arising out of an insurance policy was not covered by the arbitration provision in the parties separate premium payment agreement because if the party had intended to subject this dispute to the arbitration provision it could easily clearly and unequivocally have done so either by including an arbitration provision in the insurance policy itself or by adding to the above arbitration provision