Image Software, Inc. v. Reynolds & Reynolds Co.

                                                                      F IL E D
                                                                United States Court of Appeals
                                                                        Tenth Circuit
                                   PU BL ISH
                                                                      August 23, 2006
                 U N IT E D ST A T E S C O U R T O F A P PE A L S
                                                                    Elisabeth A. Shumaker
                                                                        Clerk of Court
                              T E N T H C IR C U IT




1M AGE SOFTW ARE, IN C., a
Colorado corporation,

     Plaintiff - Appellant,
v.

TH E REY N O LD S A N D REY N OLDS
COM PA NY, an Ohio corporation;
COLORADO IM PORT M OTORS
LIM ITED, a Colorado corporation;
DELLENBACH CHEVROLET, IN C.,
a Colorado corporation; M IK E
NAUGHTON FORD, IN C., a
Colorado corporation; OW EN
FARIC Y M OTOR COM PANY, a
C olorado corporation; G EB HA RDT
AUTOM OTIVE, INC., a Colorado                           No. 04-1533
corporation; M C CA D D O N
OLDSM OBILE-CADILLAC, IN C., a
C olorado corporation; B RO A D WAY
DODGE, a Colorado corporation;
FISCHER CHEVROLET, IN C., a
C olorado corporation; G LEN WOOD
SPR INGS M OTORS, a Colorado
corporation; KARICO, INC. (Pro-Chry
Jeep), a Colorado corporation; KORF
M OTORS, a Colorado corporation;
LUBY CHEVROLET, a Colorado
corporation; M ARKLEY M OTORS, a
Colorado corporation; M EDV ED
CHEVROLET, INC., a Colorado
corporation; PENKHUS M OTOR, a
Colorado corporation; RO TH
 CHEVROLET, INC., a Colorado
 corporation; SELLERS, IN C, a
 Colorado corporation; W EAV ER
 BEATTY, a Colorado corporation,

       Defendants - Appellees.



                  A ppeal from the U nited States D istrict C ourt
                           for the D istrict of C olorado
                            (D .C . N o. 02-K -1688-JL K )


James A. Jablonski, Gorsuch Kirgis LLP, Denver, Colorado, for
Plaintiff - A ppellant.

David A. Rabin, M orris, M anning & M artin, L.L.P., Atlanta, Georgia (Jo Ann M .
Zboyan, Springer & Steinberg, P.C., Denver, Colorado, and Jeffrey S. George,
Hogan & Hartson, L.L.P., Colorado Springs, Colorado, with him on the briefs),
for D efendants - A ppellees.


Before T A C H A , Chief Judge, E B E L, and M cC O N N E L L , Circuit Judges.


E B E L, Circuit Judge.


      1mage Software, Inc. (“1mage”) appeals the district court’s decision

compelling arbitration, in Ohio, of a dispute arising under a software licensing

agreem ent. B efore reaching the merits of this appeal, we must address two

potential problems with the district court’s jurisdiction. First, we conclude the

district court had subject matter jurisdiction based upon the federal question

presented by 1mage’s claim asserted under the Copyright Act. In reaching this

                                           2
conclusion, we adopt the Second Circuit’s analysis for distinguishing between

state-law claims alleging breach of a contract involving copyrighted matters and

those asserting an actual controversy under the federal Copyright Act. Second,

although this court has previously held, in Ansari v. Qwest Communications

Corp., 414 F.3d 1214 (10th Cir. 2005), that a district court does not have the

authority under the Federal Arbitration Act (FA A”), 9 U.S.C. § 4, to compel

arbitration in another district, this was not a jurisdictional prerequisite, but was

instead a venue requirement that the parties have waived in this case. Reaching

the merits, we AFFIRM the district court’s decision to compel arbitration.

I.    BACKGROUND1

      1mage creates computer document imaging software used by the

automotive industry. Defendant-Appellee Reynolds and Reynolds Company

(“Reynolds”) sought to market 1mage’s software, primarily to car dealerships. To

that end, 1mage and Reynolds entered into a licensing agreement on M ay 4, 1994

(“1994 agreement”). 2 Through that agreement, 1mage granted Reynolds a

perpetual license to use, market and distribute 1mage’s software. The parties also

agreed to arbitrate any dispute arising from this licensing agreement. Any such


      1
       Like the district court, we rely on the undisputed allegations of the parties
for these background facts.
      2
       The 1994 agreement was between 1mage, its parent company, Information
Software, Inc. (“ISI”), and Reynolds. The 1994 agreement’s references to ISI
included both ISI and 1mage.

                                           3
arbitration was to occur in Dayton, Ohio.

      Two years later, in 1996, 1mage and Reynolds entered into a “M aintenance

Agreement” (“1996 agreement”) for the software 1mage had licensed Reynolds to

use through the previous 1994 agreement. In addition, through this 1996

agreement, Reynolds obtained a newer version of 1mage’s software, Release 5.5.

Although this 1996 agreement did not include an arbitration provision, it did

contain a merger clause which provided that “[t]his Agreement is the exclusive

statement of the entire agreement between 1M AGE and [Reynolds] and

supersedes all prior oral or written representations or agreements between the

parties, except the Software Licensing Agreement dated M ay 4, 1994.”

(Emphasis added.) The 1996 agreement further provided that either party could

terminate that maintenance agreement w ith ninety days’ notice to the other party.

Reynolds renewed the maintenance agreement for several years by paying an

annual maintenance fee, but in January 2002 it notified 1mage that it had decided

to terminate the maintenance agreement effective April 21, 2002. In response,

1mage informed Reynolds that it no longer had any license to use 1mage’s

Release 5.5 software. W hen Reynolds continued using and marketing

Release 5.5, 1mage sued Reynolds, along with nineteen car dealers who had

obtained 1mage’s software from Reynolds (collectively “Defendants”). 1mage

commenced this litigation in federal court in Colorado, alleging three claims:



                                            4
1) Defendants were infringing on 1mage’s copyrighted software, in violation of

the Copyright Act, 17 U.S.C. §§ 101-1332; 2) Reynolds had misappropriated

1mage’s trade secrets, contrary to Colo. Rev. Stat. §§ 7-74-101 through -110; and

3) an accounting of Reynolds’s revenues w as needed in light of Reynolds’s

copyright and trade-secrets violations.

      Pursuant to the Federal Arbitration Act (“FAA”), Reynolds filed a motion

under 9 U.S.C. §§ 3 and 4 to stay the federal litigation and to compel arbitration

of these claims. 3 The district court granted that motion. See 1mage Software,

Inc. v. R eynolds & R eynolds C o., 273 F. Supp. 2d 1168 (D. Colo. 2003). An

arbitrator in Ohio ultimately aw arded Reynolds just under $400,000 in damages.

The district court confirmed the arbitrator’s judgment and award. 1mage now

appeals, challenging the district court’s order and jurisdiction granting Reynolds’




      3
          The FAA provides that

      [i]f any suit or proceeding be brought in any of the courts of the United
      States upon any issue referable to arbitration under an agreement in
      writing for such arbitration, the court in which such suit is pending,
      upon being satisfied that the issue involved in such suit or proceeding
      is referable to arbitration under such an agreement, shall on application
      of one of the parties stay the trial of the action until such arbitration has
      been had in accordance with the terms of the agreement, providing the
      applicant for the stay is not in default in proceeding with such
      arbitration.

9 U.S.C. § 3. As explained in greater detail below, § 4 sets forth the procedures
by which a party can seek to enforce an agreement to arbitrate.

                                           5
motion to compel arbitration. Having jurisdiction under 9 U.S.C. § 16(a)(3) 4 and

28 U.S.C. § 1291 to consider this appeal from the district court’s final judgment,

we AFFIRM the district court’s decision.

II.      ISSU E S

         A.    W hether the district court had subject m atter jurisdiction.

         Federal courts “have an independent obligation to determine whether

subject-matter jurisdiction exists, even in the absence of a challenge from any

party,” and thus a court may sua sponte raise the question of whether there is

subject matter jurisdiction “at any stage in the litigation.” A rbaugh v. Y & H

Corp., — U.S. — , 126 S. Ct. 1235, 1240, 1244 (2006). W hile the parties in this

case never questioned the federal courts’ subject matter jurisdiction over this

action, the district court itself raised its own concern about it, but ultimately

concluded it did have subject matter jurisdiction. See 1mage Software, Inc., 273

F. Supp. 2d at 1171. After considering the issue, we agree.

               1.    Standard of review

         This court review s “de novo whether subject matter jurisdiction is proper in

this case.” A ustralian Gold, Inc. v. Hatfield, 436 F.3d 1228, 1234 (10th Cir.

2006).




         4
        9 U.S.C. § 16(a)(3) provides that “[a]n appeal may be taken from . . . a
final decision with respect to an arbitration that is subject to this title.”

                                           6
             2.     A nalysis

      In its complaint, 1mage invoked the federal courts’ subject matter

jurisdiction under 28 U.S.C. § 1331, which provides that “[t]he district courts

shall have original jurisdiction of all civil actions arising under the Constitution,

laws, or treaties of the United States;” 5 and 28 U.S.C. § 1338(a), which further

provides that “[t]he district courts shall have original jurisdiction of any civil

action arising under any Act of Congress relating to patents, plant variety

protection, copyrights and trademarks. Such jurisdiction shall be exclusive of the

courts of the states in patent, plant variety protection and copyright cases.”

(Emphasis added.) Because the only federal-law claim 1mage alleged was its

claim under the Copyright Act, the district court’s subject matter jurisdiction rests

solely on that claim. 6 The district court’s concern with its jurisdiction was that,


      5
       “A case ‘arises under’ federal law within the meaning of § 1331 . . . if a
well-pleaded complaint establishes either that federal law creates the cause of
action or that the plaintiff’s right to relief necessarily depends on resolution of a
substantial question of federal law.” Empire Healthchoice Assurance, Inc. v.
M cVeigh, — U.S. — , 126 S. Ct. 2121, 2131 (2006) (alteration, quotations
omitted).
      6
        Although the district court indicated 1mage also asserted the district court
had subject matter jurisdiction based on diversity, see 1mage Software, Inc., 273
F. Supp. 2d at 1171, that cannot be the case because the parties are not
diverse–both 1mage and the auto dealers 1mage sued are Colorado corporations.
See 28 U.S.C. § 1332(a)(1), (c)(1); see also Radil v. Sanborn W . Camps, Inc., 384
F.3d 1220, 1225 (10th Cir. 2004) (noting that, “to establish subject matter
jurisdiction under 28 U.S.C. § 1332, a party must show that compete diversity of
citizenship exists between the parties and that the amount in controversy exceeds
                                                                       (continued...)

                                           7
while 1mage pled a claim under the Copyright Act, that claim was based upon

1mage’s allegations implicating the parties’ 1994 and 1996 agreements. If

1mage’s copyright claim was actually a state-law breach-of-contract claim that

just happened to involve copyrighted material, then it would not be sufficient to

invoke the district court’s subject matter jurisdiction. See 1mage Softw are, Inc.,

273 F. Supp. 2d at 1171.   Nevertheless, the district court concluded that it had

subject matter jurisdiction in this case because 1mage had, in its complaint,

requested a remedy “expressly provided under the [Copyright] Act.” Id. In




      6
        (...continued)
$75,000”). 1mage also asserted a trade-secrets claim, but it did so under
Colorado law . The district court would have had supplemental jurisdiction to
consider this Colorado law claim, see 28 U.S.C. § 1367, only if it had subject
matter jurisdiction in the first place. See Nicodemus v. Union Pac. Corp., 440
F.3d 1227, 1235 n.8 (10th Cir. 2006) (noting that, under 28 U.S.C. § 1367, “[i]f
any one claim within Plaintiffs’ complaint supports federal question jurisdiction,
a federal court may assert jurisdiction over all the claims, including any alleged
state-law claims, arising from the same core of operative facts”). So the question
of w hether the district court had subject matter jurisdiction to consider 1mage’s
action turns solely on 1mage’s claim asserted under the federal Copyright Act.

       And, although Reynolds, as a defendant, later invoked the Federal
Arbitration Act, that act itself does not confer federal jurisdiction over a
proceeding. See M oses H. Cone M em’l Hosp. v. M ercury Constr. Corp., 460 U.S.
1, 26 n.32 (1983); U. S. Energy Corp. v. Nukem, Inc., 400 F.3d 822, 829 (10th
Cir. 2005); 3 Federal Procedure, L. Ed. § 4:36 (1981); see also 13B Charles Alan
W right, et al., Federal Practice and Procedure § 3569 (2d ed. 1984). Rather, there
must still be an independent basis for the district court’s subject matter
jurisdiction. See M oses H. Cone M em’l Hosp., 460 U .S. at 26 n.32; see also
3 Federal Procedure, L. Ed. § 4:36; 13B W right, et al., Federal Practice &
Procedure § 3569.

                                         8
reaching this conclusion, the district court relied on Second Circuit authority. See

id. (citing Bassett v. M ashantucket Pequot Tribe, 204 F.3d 343 (2d Cir. 2000),

and T.B. Harms Co. v. Eliscu, 339 F.2d 823 (2d Cir. 1964)). W e agree with that

authority and take this opportunity to adopt the Second Circuit’s analytical

approach.

      The Second Circuit has set forth “[t]he most frequently cited test” for

determining whether an action arises under the Copyright Act. Gener-Villar v.

Adcom G roup, Inc., 417 F.3d 201, 203 (1st Cir. 2005). “It is well-established that

not every complaint that refers to the Copyright Act ‘arises under’ that law for

purposes of [28 U.S.C. §] 1338(a).” Bassett, 204 F.3d at 347 (quoting 28 U.S.C.

§ 1338(a)). “In particular, the federal grant of a copyright has not been thought to

infuse with any national interest a dispute as to ownership or contractual

enforcement turning on the facts or on ordinary principles of contract law.” Id.

(quotations, alteration omitted).

      W hether a complaint asserting factually related copyright and contract
      claims “arises under” the federal copyright laws for the purposes of
      Section 1338(a) “poses among the knottiest procedural problems in
      copyright jurisprudence.” 3 M elville B. Nimmer & David N immer,
      Nimmer on Copyright § 12.01[A], at 12-4 (1999). . . . Such claims
      characteristically arise where the defendant held a license to exploit the
      plaintiff’s copyright, but is alleged to have forfeited the license by
      breaching the terms of the licensing contract and thus to infringe in any
      further exploitation.




                                          9
Id. 7

        District courts in the Second Circuit had previously sought to

        resolve[] the issue of jurisdiction under Section 1338 for “hybrid”
        claims raising both copyright and contract issues by attempting to
        discern whether the copyright issues constituted the “essence” of the
        dispute, or whether instead the copyright issues were “incidental to” the
        contract dispute.

                 ....

              That approach, however, left a class of plaintiffs who suffered
        copyright infringement bereft of copyright remedies. Plaintiffs whose
        federal lawsuits were dismissed for lack of subject matter jurisdiction
        on the ground that their copyright claims w ere “incidental to” their
        contract claims had no way either to obtain an adjudication of



        7
            In the same vein, the Ninth Circuit has noted that, although

        [t]he federal courts have exclusive jurisdiction over “any civil action
        arising under any Act of Congress relating to . . . copyrights[,]” . . . it
        is well established that just because a case involves a copyright does not
        mean that federal subject matter jurisdiction exists. Federal courts have
        consistently dismissed complaints in copyright cases presenting only
        questions of contract law . A s a result, the federal courts walk a fine
        line between usurping the power of the state courts and providing
        redress for copyright infringement. This balancing act is further
        complicated by the interdependence of contract and copyright claims,
        which can camouflage the genuine issues to be resolved.

Scholastic Entm’t, Inc. v. Fox Entm’t Group, Inc., 336 F.3d 982, 985-86 (9th Cir.
2003) (quoting 28 U.S.C. § 1338; citations omitted); see also 13B Charles Alan
W right, et al., Federal Practice & Procedure § 3582 (“A suit on a contract does
not ‘arise under’ the copyright laws even though a copyright may have been the
subject matter of the contract. M ost disputes about ownership of a copyright do
not arise under the copyright laws for purposes of jurisdiction, although there can
be a different result if the case raises an important issue of interpretation of the
Copyright Act.”) (footnotes omitted).

                                             10
      infringement or to obtain relief provided by the Copyright Act, because
      the Act confers exclusive jurisdiction over copyright claims on federal
      courts. Such plaintiffs w ould be deprived of the injunctive relief,
      impoundment remedies, statutory damages, and attorneys fees provided
      by the [Copyright] Act. That approach had the added defect of
      requiring a [federal] court to make findings at the outset of the
      litigation that could not be discerned from the complaint but instead
      required a deep understanding of the dispute not usually gained until the
      case had been heard at trial.

Id. at 347-48 (citations omitted).

      The Second Circuit’s solution to this jurisdictional problem was to

“establish[] a test . . . that focused on whether and how a complaint implicates the

Copyright Act.” Id. at 348. Thus, “the analysis . . . turns on what is alleged on

the face of the complaint.” Id. at 349. Applying that test, “a suit ‘arises under’

the Copyright Act if: (1) The complaint is for a remedy expressly granted by the

Act, e.g., a suit for infringement . . . ; or, (2) The complaint asserts a claim

requiring construction of the Act.” 8 Id. at 349 (quotations, alterations omitted);

see also id. at 355. This test “is essentially a reiteration of the ‘well-pleaded

complaint’ rule that federal jurisdiction exists only when a federal question is



      8
       The Second Circuit noted that “jurisdiction might also exist, ‘perhaps more
doubtfully,’ in a third category of case, ‘where a distinctive policy of the
[Copyright] Act requires that federal principles control the disposition of the
claim.’” Bassett, 204 F.3d at 349 n.3 (quoting T.B. Harms, 339 F.2d at 828); see
also Scholastic Entm’t, Inc., 336 F.3d at 986 (stating Second Circuit’s rule to
“require[] the district court to exercise jurisdiction if: (1) the complaint asks for a
remedy expressly granted by the Copyright Act; (2) the complaint requires an
interpretation of the Copyright Act; or (3) federal principles should control the
claims”).

                                           11
presented on the face of a properly pleaded complaint.” Scholastic Entm’t, Inc.,

336 F.3d at 986.

      W e join a number of other circuits in adopting the Second Circuit’s

approach to this difficult jurisdictional issue. 9 See Bassett, 204 F.3d at 349-51

(citing authority 1 0 ); see also Scandinavian Satellite Sys. v. Prime TV Ltd., 291

F.3d 839, 844 (D.C. Cir. 2002) (also adopting Second Circuit’s analytical

approach).

      Applying the Second Circuit’s test to this case, it is clear that the district

court had subject matter jurisdiction over 1mage’s copyright claim under

28 U.S.C. § 1338(a). 1mage, in its complaint, specifically alleged a claim under


      9
       In an analogous situation, this court, in Ausherman v. Stump, 643 F.2d 715
(10th Cir. 1981), previously held that federal courts did not have jurisdiction
under 28 U.S.C. § 1338(a) over a suit “brought on a contract” involving patents.
643 F.2d at 716, 718. In reaching that conclusion, this court focused on the
complaint as pled, noting that “the complaint does not set forth a valid patent
infringement claim,” despite “the fact that Ausherman had liberally sprinkled the
word ‘infringement’ throughout his pleadings.” Id. The approach this court took
in Ausherman is consistent with the Second Circuit’s test w e now adopt.
      10
        The Second Circuit, in Bassett, 204 F.3d at 350-51, noted the First,
Fourth, Fifth, Ninth and Eleventh Circuits had adopted the Second Circuit’s
approach to this jurisdictional determination: Royal v. Leading Edge Prods., Inc.,
833 F.2d 1, 2 (1st Cir. 1987); Gibraltar, P.R., Inc. v. Otoki Group, Inc., 104 F.3d
616, 619 (4th Cir. 1997); Arthur Young & Co. v. City of Richmond, 895 F.2d
967, 969-70 (4th Cir. 1990); Goodman v. Lee, 815 F.2d 1030, 1031 (5th Cir.
1987); Rano v. Sipa Press, Inc., 987 F.2d 580, 584 (9th Cir. 1993); Vestron, Inc.
v. Home Box Office Inc., 839 F.2d 1380, 1381 (9th Cir. 1988); M CA Television
Ltd. v. Pub. Interest Corp., 171 F.3d 1265, 1269-70 (11th Cir. 1999); see also
Gener-Villar, 417 F.3d at 203-04 (reaffirming that First Circuit has adopted
Second Circuit’s analysis).

                                          12
the Copyright Act for copyright infringement, see 17 U.S.C. § 501, and sought

actual damages and profits or, in the alternative, statutory damages, as well as

costs and attorney’s fees specifically provided for under the Copyright Act, see id.

§§ 504-05. Based upon those allegations, the district court properly concluded

that it had subject matter jurisdiction over 1mage’s copyright claim. See Bassett,

204 F.3d at 355-56 (holding federal court had subject matter jurisdiction because

plaintiff had alleged copyright infringement and sought injunctive remedy

provided for by the Copyright Act); see also M CA Television Ltd., 171 F.3d at

1269-70 (holding federal court had subject matter jurisdiction over copyright

infringement claim seeking preliminary injunction and damages provided for by

the Copyright Act); Rano, 987 F.2d at 584 (holding federal court had subject

matter jurisdiction over claim seeking injunction, impoundment, “damages and

profits,” and attorney’s fees provided for under Copyright Act); Arthur Young &

Co., 895 F.2d at 971 (holding federal court had subject matter jurisdiction over

claim alleging copyright infringement and seeking damages and injunctive relief

under Copyright Act); Vestron, Inc., 839 F.2d at 1381-82 (holding federal court

had subject matter jurisdiction over claim for copyright infringement seeking an

injunction, “damages and profits,” costs and attorney’s fees under Copyright Act).

      B.     W hether the C olorado district court could com pel arbitration in
             O hio.

      This case presents a second possible jurisdictional problem. In Ansari, w e

                                         13
held that a district court does not have authority to compel arbitration in another

district. 1 1 See 414 F.3d at 1219-20. Yet, in this case, the Colorado district court

granted Reynolds’s motion to compel arbitration in Ohio. At the time, neither

party questioned the district court’s authority to do so. 1 2 The question presented

by this appeal, then, is whether the rule announced in Ansari is jurisdictional; that

is, whether the district court was w ithout any power to adjudicate Reynolds’s

motion to compel arbitration. W e conclude that Ansari did not state a

jurisdictional prerequisite; rather, Ansari’s rule is one of venue which the parties

in this case have waived by not raising the issue before the district court. 1 3 See



      11
         Ansari further held that a district court is also without authority to compel
arbitration in its own district if that would contravene the forum-selection
provisions in the arbitration agreement. See 414 F.3d at 1219-20. That aspect of
Ansari is not at issue in this case because neither party argues that the district
court should have compelled arbitration in Colorado, contrary to their 1994
agreement.
      12
         1mage did contest the motion to compel arbitration generally, but it did
not raise this particular challenge to the district court’s authority to compel
arbitration.
      13

            Venue is som etim es confused with jurisdiction. [However,] the
      two concepts are quite different. As the Supreme Court put it in a
      leading case:

             The jurisdiction of the federal courts – their power to
             adjudicate – is a grant of authority to them by Congress
             and thus beyond the scope of litigants to confer. But the
             locality of a law suit – the place where judicial authority
             m ay be exercised – though defined by legislation relates to
                                                                        (continued...)

                                          14
Harris Capital Fund, LLC v. Grillo, 160 F. App’x 727, 728 (10th Cir. 2005)

(unpublished) (treating Ansari as addressing venue).

                1.    Standard of review

      W e review this possible jurisdictional problem de novo. See Huerta v.

Gonzales, 443 F.3d 753, 755 (10th Cir. 2006) (noting “we review issues of

jurisdiction de novo”).

                2.    A nalysis

      Ansari based its decision that a district court did not have the authority to

compel arbitration in another district on the language of 9 U.S.C. § 4. See



      13
           (...continued)
                 the convenience of litigants and as such is subject to their
                 disposition. This basic difference betw een the court’s
                 power and the litigant’s convenience is historic in the
                 federal courts.

             This distinction between the court’s power to adjudicate and the
      place where that authority m ay be exercised must always be recognized.
      It has two im portant consequences.          Because venue is for the
      convenience of litigants it is a personal privilege of the defendants and
      can be waived by them. In this respect it is sim ilar to jurisdiction over
      the person of defendants, which also can be waived, but unlike
      jurisdiction of the subject m atter, which cannot be waived by the
      parties. The other consequence is that if the statutory rules on venue
      are not followed, and objection is m ade on the ground of im proper
      venue, the action cannot be heard in that district, even though the court
      m ay have jurisdiction over the subject m atter and over the defendants.

15 Charles Alan W right, et al., Federal Practice & Procedure § 3801 (2d ed. 1986)
(quoting Neirbo Co. v. Bethlehem Shipbuilding Corp., 308 U.S. 165, 167-68
(1939)) (footnotes, further quotation om itted).

                                             15
Ansari, 414 F.3d at 1218-20. Section 4 addresses motions to enforce arbitration

agreements by compelling arbitration and specifically provides that “[t]he hearing

and proceedings, under such agreement [to arbitrate], shall be within the district

in which the petition for an order directing such arbitration is filed.” 1 4 Other

circuits have referred to this language in § 4 as a venue provision. See Dumont v.

Saskatchewan Gov’t Ins., 258 F.3d 880, 887-88 (8th Cir. 2001); Doctor’s Assocs.,

Inc. v. Stuart, 85 F.3d 975, 983 (2d Cir. 1996); M errill Lynch, Pierce, Fenner, &

Smith, Inc. v. Lauer, 49 F.3d 323, 327 (7th Cir. 1995); Econo-Car Int’l, Inc. v.

Antilles Car Rentals, Inc., 499 F.2d 1391, 1394 & n.14 (3d Cir. 1974); Farr & Co.

v. Cia. Intercontinental de N avegacion de Cuba, 243 F.2d 342, 346 (2d Cir.



      14
           M ore fully, 9 U.S.C. § 4 provides in relevant part:

              A party aggrieved by the alleged failure, neglect, or refusal of
      another to arbitrate under a written agreement for arbitration may
      petition any United States district court which, save for such agreement,
      would have jurisdiction under Title 28, in a civil action or in admiralty
      of the subject matter of a suit arising out of the controversy between the
      parties, for an order directing that such arbitration proceed in a manner
      provided for in such agreement. . . . The court shall hear the parties,
      and upon being satisfied that the making of the agreement for
      arbitration or the failure to comply therewith is not in issue, the court
      shall make an order directing the parties to proceed to arbitration in
      accordance w ith the terms of the agreement. The hearing and
      proceedings, under such agreement, shall be w ithin the district in which
      the petition for an order directing such arbitration is filed. If the
      making of the arbitration agreement or the failure, neglect or refusal to
      perform the same be in issue, the court shall proceed summarily to the
      trial thereof.


                                            16
1957); see also John W . Hinchey & Thomas V. Burch, The Effect of

Forum-Selection Clauses on a District Court’s Pow er to Compel Arbitration, 60

Disp. Resol. J. 55, 55, 56-57 (Nov. 2005-Jan. 2006); Venue of M otion to Compel,

60 Disp. Resol. J. 91 (Aug-Oct. 2005). M ost relevant to this case, the Third and

Seventh Circuits specifically referred to § 4 as a venue provision even as they

held that under § 4’s mandatory language, a district court could not compel

arbitration in another district. See Lauer, 49 F.3d at 327-28; Econo-Car Int’l,

Inc., 499 F.2d at 1394.

      And courts have analogously treated other, similar FA A provisions as

venue requirements. In Cortez Byrd Chips, Inc. v. Bill H arbert Construction Co.,

529 U.S. 193 (2000), for example, the Supreme Court specifically addressed

9 U.S.C. §§ 9-11 as venue provisions. Id. at 195. Like § 4, 9 U.S.C. §§ 9-11

specify in which court certain arbitration proceedings under the FAA should take

place. 1 5 In Cortez Bird Chips, Inc., the Supreme Court held that §§ 9-11 were



      15
           Section 9 provides, in relevant part:

      If the parties in their agreem ent have agreed that a judgment of the
      court shall be entered upon the award made pursuant to the arbitration,
      and shall specify the court, then at any time within one year after the
      award is made any party to the arbitration may apply to the court so
      specified for an order confirming the award, and thereupon the court
      must grant such an order unless the award is vacated, modified, or
      corrected as prescribed in sections 10 and 11 of this title. If no court
      is specified in the agreement of the parties, then such application m ay
                                                                       (continued...)

                                            17
permissive (rather than restrictive) venue provisions. See 529 U.S. at 195, 204.

Although this court, in Ansari, distinguished the permissive venue provisions at

issue in Cortez Bird Chips, Inc. from § 4, which instead uses “mandatory”

language, see Ansari, 414 F.3d at 1219, that distinction does not make § 4 any

less a venue provision.

      Congress has established “general venue statutes” in 28 U.S.C.

§§ 1391-92. 1 6 15 Charles Alan W right, et al., Federal Practice and Procedure


      15
        (...continued)
      be made to the United States court in and for the district within which
      such award was made. Notice of the application shall be served upon
      the adverse party, and thereupon the court shall have jurisdiction of
      such party as though he had appeared generally in the proceeding.

And 9 U.S.C. §§ 10 and 11 authorize the “United States court in and for the
district wherein the [arbitration] award was made” to vacate, modify or correct
that award.
      16
        In part, those general venue statutes provide that for a case in federal
court based only upon diversity jurisdiction, venue is proper,

      except as otherwise provided by law, . . . only in (1) a judicial district
      where any defendant resides, if all defendants reside in the same State,
      (2) a judicial district in which a substantial part of the events or
      om issions giving rise to the claim occurred, or a substantial part of the
      property that is the subject of the action is situated, or (3) a judicial
      district in which any defendant is subject to personal jurisdiction at the
      tim e the action is comm enced, if there is no district in which the action
      m ay otherw ise be brought.

28 U.S.C. § 1391(a). And for a case where “jurisdiction is not founded solely
upon diversity of citizenship,” venue is proper,

                                                                         (continued...)

                                          18
§ 3804; see also id. § 3803; 17 M oore’s Federal Practice § 110.01[3][a] (3d ed.

2006). In addition, however, Congress has also created “special” venue statutes.

See 15 Charles Alan W right, et al., Federal Practice & Procedure § 3804. “A

special venue statute, expressly covering venue of a particular kind of action, will

control over the general venue statutes, but provisions in the general statutes are

read as supplementing the special statute in the absence of contrary restrictive

indications in the special statute.” Id. § 3803 (emphasis added; footnotes

om itted); see also id. § 3804; 17 M oore’s Federal Practice § 110.01[3][b]

(referring to restrictive venue provisions as “exclusive”). It may be that § 4’s

mandatory language makes it a restrictive rather than a permissive venue

provision. See Cortez Bird Chips, Inc., 529 U.S. at 195, 197-204 (discussing

distinction between permissive and restrictive venue provisions in concluding 9

U.S.C. §§ 9-11 are permissive venue provisions); Ansari, 414 F.3d at 1220.

However, parties can waive objections under restrictive venue provisions, just as

they can under general venue provisions. See Radzanower v. Touche Ross & Co.,


      16
        (...continued)
      except as otherwise provided by law, . . . only in (1) the judicial district
      where any defendant resides, if all defendants reside in the same State,
      (2) a judicial district in which a substantial part of the events or
      om issions giving rise to the claim occurred, or a substantial part of the
      property that is the subject of the action is situated, or (3) a judicial
      district in which any defendant may be found, if there is no district in
      which the action m ay otherw ise be brought.

Id. § 1391(b).

                                          19
426 U.S. 148, 149-51 (1976) (noting “[i]t has long been settled that the restrictive

venue provisions of [the National Bank Act, 12 U.S.C.] § 94 can be waived by a

defendant bank”); Interstate Commerce Comm’n v. Atl. Coast Line R. Co., 383

U.S. 576, 577, 579, 597 n.8 (1966) (noting waiver applied to Interstate Commerce

Act’s restrictive venue provisions); Am. Chem. Paint Co. v. Dow Chem. Co., 161

F.2d 956, 958-59 (2d Cir. 1947) (addressing whether parties had waived objection

to venue under 28 U.S.C. § 48, providing for exclusive venue in patent

infringement cases); Luper v. Capital Conveyor (In re Lee W ay Holding Co.), 104

B. R. 881, 885 (Bankr. S.D. Ohio 1989) (noting “[e]ven restrictive venue

provisions can be waived”); see also 15 Charles Alan W right, et al., Federal

Practice and Procedure § 3813 (noting party can waive venue provided by

restrictive, as well as general, venue provisions).

      Further, treating these FAA provisions as venue provisions makes sense in

light of the fact that the FAA does not itself confer subject matter jurisdiction.

See M oses H. Cone M em’l Hosp., 460 U.S. at 26 n.32; Nukem, Inc., 400 F.3d at

829. And in fact, an earlier provision of § 4 addresses the need for a

jurisdictional basis independent of the FAA, indicating that a party seeking to

compel arbitration may do so in “any United States district court which, save for

such [arbitration] agreement, would have jurisdiction under Title 28, in a civil

action or in admiralty of the subject matter of a suit arising out of the controversy



                                          20
between the parties.” Finally, § 4 serves the purposes venue statutes traditionally

serve; that is, it “refers to locality, the place where a lawsuit should be heard.” 15

Charles Alan W right, Federal Practice & Procedure, § 3801.

      For these reasons, we conclude that Ansari’s holding that a district court

does not have authority to compel arbitration in another district is a statement

addressing venue under the FA A. 1 7 And the parties in this case have waived any

objection to venue because they failed to raise the issue in the district court. See

generally Stjernholm v. Peterson, 83 F.3d 347, 349 (10th Cir. 1996) (noting

parties can waive objection to venue by failing to raise the issue in timely manner

before district court); 15 Charles Alan W right, et al., Federal Practice &

Procedure, § 3826.

      C.     W hether the district court erred in granting R eynolds’s m otion
             to com pel arbitration of the parties’ dispute.

      Turning to the merits of this appeal, 1mage argues that the district court

erred in compelling the parties to arbitrate their dispute pursuant to the 1994

agreement. W e disagree.

             1.      Standard of review



      17
        Because we conclude Ansari did not deprive the district court of its ability
to adjudicate Reynolds’s motion to compel arbitration, we need not address
Reynolds’s additional argument that 9 U.S.C. § 3, permitting a court to stay
pending litigation while the parties arbitrate, provided the district court in this
case with an alternate jurisdictional basis to adjudicate R eynolds’s motion to
compel arbitration.

                                          21
      This court reviews the district court’s decision on a motion to compel

arbitration de novo, employing the same legal standards the district court

employed. See Ansari, 414 F.3d at 1218.

             2.     A nalysis

      The FAA “manifests a liberal federal policy favoring arbitration.”

Comanche Indian Tribe v. 49, L.L.C., 391 F.3d 1129, 1131 (10th Cir. 2004)

(quotations omitted). Nonetheless, “arbitration is a matter of contract and a party

cannot be required to submit to arbitration any dispute which he has not agreed so

to submit.” Howsam v. Dean Witter Reynolds, Inc., 537 U.S. 79, 83 (2002)

(quotations omitted). “Absent some ambiguity in the [arbitration]

agreement, . . . it is the language of the contract that defines the scope of disputes

subject to arbitration.” E.E.O.C. v. W affle House, Inc., 534 U.S. 279, 289 (2002).

“As with any other contract, the parties’ intentions control, but those intentions

are generously construed as to issues of arbitrability.” W illiams v. Imhoff, 203

F.3d 758, 764 (10th Cir. 2000) (alteration, quotations omitted).

      In this case, 1mage and Reynolds agreed to arbitrate “any dispute [that]

occurs between the parties arising out of or related to [the 1994] A greement or its

negotiation, execution or performance, whether such dispute is in contract, tort or




                                          22
otherwise.” 1 8 In substance, through the 1994 licensing agreement, 1mage granted

Reynolds

      a perpetual, fully paid-up, royalty-free, worldwide right and license:

               A. to use, demonstrate, copy, and m odify . . . the ISI
               Software 1 9 . . . , and

               B.   to distribute, lease, market and sublicense the ISI
               Software . . . ,

      . . . on a non-exclusive basis in the automotive industry and automotive
      after market (including manufacturers, non-dealer body shops, and parts


      18
           M ore fully, the 1994 agreement provided:

      If any dispute occurs between the parties arising out of or related to this
      Agreement or its negotiation, execution or performance, w hether such
      dispute is in contract, tort or otherwise, it will be submitted first to
      mediation under the mediation rules of the American Arbitration
      Association. Should the mediation fail, the dispute will be submitted
      to arbitration. . . . Any mediation or arbitration will be held and the
      award deemed m ade in Dayton, Ohio. . . . The decision and award of
      the arbitrator w ill be final and binding and the award given may be
      entered in any court of competent jurisdiction. The parties will be
      entitled to discovery to the same extent provided for civil actions in the
      Southern District of the State of Ohio. The parties agree to be bound
      by the decision of the arbitrator and judgment upon the award rendered
      thereby may be entered in any court having jurisdiction within the
      Southern District of Ohio. The parties hereby submit to the in
      personam jurisdiction of the courts of the State of O hio for all purposes
      of this Section and any disputes arising under this Agreement. The
      Federal Arbitration Act (9 U.S.C. Sections 1-15), not state law , will
      govern the arbitrability of all claims and all aspects of the arbitration.


      19
        The 1994 licensing agreement included, not only 1mage’s document
imaging software, but also related software which the agreement referred to
together as the “ISI Software.”

                                          23
      suppliers), and to other businesses under common control with an
      automotive sublicensee[; and]

            ....

      on an exclusive basis . . . to establishments prim arily engaged in retail
      sales of new or used automobiles, trucks or tractors . . . , except six (6)
      existing reseller agreements and contracts . . . which currently do not
      exclude the automotive dealership market . . . [; and]

            ....

      directly to end-users on a non-exclusive basis in all markets other than
      those specified [above].

(Footnote omitted.) In exchange for this license, Reynolds paid 1mage a “one

time license fee” of $ 1,750,000.

      The 1994 agreement also anticipated that Reynolds could obtain updated

software in the future. Along these lines, 1mage agreed that in the future it would

“provide to Reynolds, at no cost to Reynolds, all updates, upgrades and

enhancements to the Software, so that Reynolds may evaluate w hether it is

appropriate to make each such upgrade or enhancement generally available to its

customers.” If Reynolds chose to do so, it could then purchase those upgrades.

      Subsequent updates, upgrades, enhancements and new products
      provided by ISI will be made available to Reynolds and becom e a part
      of the ISI Software and Documentation, provided the fees (which m ay
      be no greater than fees payable by other dealers, distributors or resellers
      of the ISI Software) are agreed upon by the parties at that time.

      Two years later, in April 1996, Reynolds obtained 1mage’s updated

software, Release 5.5, as part of the parties’ “M aintenance Agreement” for the

                                          24
software 1mage had previously sold Reynolds through the 1994 agreement. The

1996 agreement provided that, in exchange for Reynolds’s payment of an “Annual

M aintenance Charge” of “$175,000 plus a $250 subscription fee for each

licensee,” 1mage would “provide subscription and maintenance service which

includes revisions, updates and enhancements,” “Repair of W arranty Defects,”

“New Versions and Releases” of the software, and “Continuing Education”

covering the software.

      The 1996 agreement did not contain an arbitration clause. But it did

include a merger clause providing that “[t]his Agreement is the exclusive

statement of the entire agreement between 1M AGE and [Reynolds] and

supersedes all prior oral or written representations or agreements between the

parties, except the Software Licensing Agreement dated M ay 4, 1994, between

Information Solutions, Inc., 1mage and [Reynolds], as to the subject matter

hereof.” (Emphasis added.)

      The 1996 agreement further provided that either party could terminate the

annual maintenance agreement after giving the other party ninety days’ notice.

After Reynolds notified 1mage that it was electing to terminate that agreement

effective April 21, 2002, 1mage asserted that Reynolds would no longer have any

license to use 1mage’s Release 5.5 software. Reynolds, on the other hand, argued

that it retained a license to use that updated software because Release 5.5 had



                                        25
been incorporated into the 1994 agreement’s perpetual license. That dispute

underlies this litigation.

      The specific question presented to the district court by Reynolds’s motion

to compel arbitration, then, was w hether this dispute arose out of or was related to

the 1994 agreement and was thus subject to that agreement’s arbitration

provision. In concluding that this dispute did arise out of or was related to the

1994 agreement, the district court recognized that that agreement not only granted

Reynolds a perpetual license in the earlier version of 1mage’s software, but it also

specifically provided for the possibility that Reynolds would acquire later updated

versions of the software from 1mage: The 1994 agreement’s section 5.2 “provides

that [s]ubsequent updates, upgrades, enhancements and new products provided by

[1mage] will be made available to Reynolds and become a part of the ISI

Software provided fees are agreed upon by the parties at that time.” 1mage

Software, Inc., 273 F. Supp. 2d at 1174 (quotations omitted). The district court

then noted that there were several plausible interpretations of the relationship

between the parties’ 1994 and 1996 agreements. First, as 1mage argued, the 1996

agreement could be a licensing agreement for Release 5.5 that was completely

separate from the 1994 perpetual licensing agreement. See id. at 1170. If so, the

license terminated when Reynolds chose to terminate the 1996 maintenance

agreement. See id. Second, as Reynolds argued, through the 1994 agreement’s



                                          26
section 5.2, the updated Release 5.5 that it obtained from 1mage through the 1996

agreement might have become part of the ISI software for which Reynolds had a

perpetual license under the 1994 licensing agreement. If so, the 1996

maintenance agreement might be just that — a maintenance agreement whose

later termination had no effect on the perpetual license, which included Release

5.5. See id. Or the 1996 agreement might have established the fees Reynolds had

agreed to pay 1mage for the updated Release 5.5, which again had been

incorporated into the original licensing agreement’s perpetual license. See id. at

1170 n. 2. Acknowledging these plausible arguments, the district court concluded

that, because Reynolds’ interpretation – that the license to use the updated

Release 5.5 software fell within the 1994 agreement’s § 5.2 and therefore had

been incorporated into the original agreement’s perpetual license – had merit, the

dispute underlying this litigation arose under that 1994 agreement and was thus

subject to arbitration. See id. at 1174. W e cannot improve on the district court’s

analysis; in light of the strong presumption of arbitrability, we agree fully with

the district court’s decision.

      In challenging the district court’s decision on appeal, 1mage relies almost

exclusively on this court’s decision in Riley M anufacturing Co. v. Anchor Glass

Container Corp., 157 F.3d 775 (10th Cir. 1998). But Riley does not require a




                                          27
different result. 2 0

       In Riley, this court addressed a situation involving two agreements between

the same parties, the first containing a provision requiring arbitration and the

second one without any arbitration provision. See id. at 777-78. These

agreements were between Riley M anufacturing Co. (“Riley”), a company that

produced “‘sun tea’ jars with copyrighted ornamental designs stenciled on” them,

and Anchor Glass Container Corp. (“Anchor”), Riley’s glass jar supplier. Id. at

776. In 1991, Riley and Anchor entered into a manufacturing and distribution

agreement (“manufacturing agreement”) under w hich “Riley agreed to provide all

of Anchor[’s] needs for sun tea jars . . . and Anchor . . . agreed to use reasonable

efforts to market Riley’s sun tea products.” Id. (quotations omitted).

       That manufacturing agreement expired in 1994. See id. at 777. In 1995,

Riley threatened to sue Anchor for copyright infringement after it purportedly

discovered that Anchor was still using Riley’s copyrighted designs. See id. The



       20
        Reynolds asserts that, because 1mage never specifically relied on Riley in
arguing against arbitration in the district court, 1mage has waived any argument
based upon Riley for appeal purposes. 1mage did later rely on Riley in its
motions seeking to have the district court vacate the arbitrator’s awards and its
pleadings arguing against confirmation of that aw ard. But 1mage generally
asserted before the district court many of the same arguments that it now asserts
on appeal, arguing that the 1996 agreement was an entirely separate agreement
from the 1994 agreement, and that the 1996 agreement was a separate licensing
agreement for the newer version of the softw are, which has now been terminated.
W e, therefore, deem 1mage to have sufficiently preserved its argument based
upon Riley.

                                         28
parties then entered into a settlement agreement to resolve the copyright dispute.

See id. That settlement agreement provided, among other things, that the parties

waived “any and all claims either party now has or could ever have or become

entitled to, which might arise under the M anufacturing Agreement.” Id.

(quotations omitted). The settlement agreement also “include[d] a series of

provisions designed to reestablish a manufacturing relationship between Riley and

Anchor,” as well as a merger clause that indicated that the 1995 settlement

agreement “constitutes the entire agreement of the parties hereto and cancels,

terminates and supersedes any and all prior representations and agreements

relating to the subject matter thereof.” Id. at 778 (quotations omitted). This 1995

settlement agreement had no arbitration provision. See id.

      Eight months after entering into the settlement agreement, Riley again

purportedly discovered that Anchor was selling sun tea jars with Riley’s

copyrighted designs. See id. This time, Riley sued Anchor, alleging, inter alia,

copyright and trade-secret claims. See id. In response, Anchor asserted that the

original manufacturing agreement required the parties to arbitrate this dispute.

See id. at 778-79. The district court disagreed and denied Anchor’s motion to

compel arbitration. See id. at 779.

      On appeal, this court reversed. See id. at 785. In doing so, we concluded

that the merger clause in the later settlement agreement, which provided that the



                                         29
settlement agreement “cancels, terminates and supersedes any and all prior

representations and agreements relating to the subject matter thereof,” id. at 778

(emphasis added), did “revoke[] the prior right of the parties to demand

arbitration” under the 1991 manufacturing agreement, but only as to the specific

subject matter of that later settlement agreement, id. at 784. The parties would

retain the right to arbitrate any dispute under the 1991 manufacturing agreement

that was not considered part of the subject matter of the later settlement

agreement. 2 1 See id.

      Riley is clearly distinguishable from this case. First, while the original

agreement in Riley had expired by its own terms, the original 1994 licensing

agreement in this case between 1mage and Reynolds expressly continues in effect.

The parties do not dispute this. M oreover, although both the later agreement in

Riley and the 1996 agreement at issue in this case had merger provisions, those

provisions are completely different. In Riley, the parties’ merger provision

“cancels, terminates and supersedes any and all prior representations and



      21
         It is for this reason that this court remanded the action in Riley in order
for the district court to determine which of Riley’s claims arose under the subject
matter of the settlement agreement and thus were not eligible for arbitration. See
Riley, 157 F.3d at 783-85. Contrary to 1mage’s assertion, Riley does not require
the district court generally to determine the subject matter of the parties’
agreements in this case. Nor does Riley hold that a second agreement without an
arbitration provision automatically precludes arbitration of any dispute related to
that second agreement. Rather, arbitrability turns on the language of the
agreements involved and the parties’ intent in creating those agreements.

                                          30
agreements relating to the subject matter thereof.” Id. at 778. The merger clause

in this case, on the other hand, specifically excepted 1mage’s and Reynolds’s

original 1994 contract: “[t]his Agreement is the exclusive statement of the entire

agreement between 1M AGE and [Reynolds] and supersedes all prior oral or

written representations or agreements between the parties, except the Software

Licensing Agreement dated M ay 4, 1994, betw een Information Solutions, Inc.,

1mage and [Reynolds], as the subject matter hereof.” (Emphasis added.) Riley,

then, does not support 1mage’s challenge to the district court’s decision to compel

arbitration in this case.

III.   C O N C L U SIO N

       For these reasons, we AFFIRM the district court’s decision.




                                         31