Outokumpu filed suit against GE in Alabama, and GE removed the case to federal court and moved to compel arbitration. Id. The district court granted GE's motion to dismiss and compel arbitration; however, the Eleventh Circuit reversed. Id. Consistent with the Ninth Circuit's ruling in Yang, the Eleventh Circuit held that as a non-signatory, GE did not satisfy the New York Convention's requirement that the parties actually sign an agreement to arbitrate their disputes, and so GE could not compel arbitration. See id. The Eleventh Circuit also held that GE as a non-signatory could not rely on state-law equitable estoppel doctrines to enforce the arbitration agreement because equitable estoppel conflicts with the New York Convention's signatory requirement. Id.