Does the rule of equitable estoppel apply in the arbitration context?

705 F.3d at 1128-29 (9th Cir. 2013) (internal citations, alterations, and quotation marks omitted); see also Murphy v. DirecTV, Inc. , 724 F.3d 1218, 1229 (9th Cir. 2013) (referring to the rule of equitable estoppel in Kramer as "a controlling statement of California law"); Mundi , 555 F.3d at 1046 ("[I]n light of the general principle that only those who have agreed to arbitrate are obliged to do so, we see no basis for extending the concept of equitable estoppel of third parties in an arbitration context beyond the very narrow confines delineated in these two [circumstances]."). Courts have reached different conclusions as to whether both circumstances must be met in order for equitable estoppel to apply.² Regardless, for the below reasons, neither circumstance applies.

[441 F.Supp.3d 970]