On December 29, 2015, the First Department issued a decision in Matter of Arbitration of Certain Controversies Between Gramercy Advisors LLC v. J.A. Green Dev. Corp., 2015 NY Slip Op. 09636, holding that parties were properly compelled to arbitrate, explaining: “The court properly enjoined the Texas action, which involves claims that are inextricably interwoven with the issues to be determined in the arbitration. Contrary to respondents’ contention based on the principles of comity, this Court has enjoined litigation in other states pending New York actions under CPLR 7503.” (Internal quotations and citations omitted) (emphasis added).