On October 17, 2013, the New York Court of Appeals refused to apply direct benefits estoppel to bind a non-signatory to arbitrate. “The mere existence of an agreement with attendant circumstances that prove advantageous to the non-signatory would not constitute the type of direct benefits justifying compelling arbitration by a non-party.” Matter of Belzberg v Verus Invs. Holdings Inc., 2013 NY Slip Op 06729.