U.S. Court of Appeals for the Second Circuit

Everything Yogurt Brands, LLC v. Bianco

September 9, 2026

Summary

The Second Circuit affirmed the district court’s dismissal for lack of personal jurisdiction, holding that the franchise agreements’ arbitration and choice‑of‑law clauses do not constitute consent to general jurisdiction in New York. The court explained that arbitration consent is limited to enforcement proceedings and that a choice‑of‑law provision alone is insufficient to establish specific jurisdiction.