Qualcomm Inc. v. Nokia Corp.
The Federal Circuit held that the district court should not determine the arbitrability of an issue asserted for arbitration if the parties had evidenced clear and unmistakable intent for arbitration by incorporating the American Association of Arbitration rules which gave such power to the arbitrator. The Federal Circuit also held that the district court must, after determining that the arbitrator had jurisdiction to determine arbitrability, determine whether the assertion of issues for arbitration was “wholly groundless” wherein the district court could refuse to submit the issues to arbitration and deny a motion to stay for arbitration.