Bloom Parham Client Prevails as Eleventh Circuit Affirms Arbitration Award

Read the full decision: Univabs Solutions Private Limited v. The Radiology Group, LLC, No. 26-10124 (11th Cir. Sept. 10, 2026).

Bloom Parham has secured an important appellate win for its client, Univabs Solutions Private Limited, after the United States Court of Appeals for the Eleventh Circuit affirmed a district court order confirming an arbitration award in Univabs’ favor. In Univabs Solutions Private Limited v. The Radiology Group, LLC, No. 26-10124 (11th Cir. Sept. 10, 2026), the court rejected two separate challenges brought by The Radiology Group, LLC (“TRG”), holding that the Federal Arbitration Act governed the parties’ dispute and that the arbitrator properly interpreted the operating agreement at the center of the case.

“We are thrilled, but not surprised, that the Eleventh Circuit applied the very clear-cut law on this topic to reject the frivolous arguments made by the appellant.  We gave them every opportunity to avoid this outcome.  From the outset, however, appellant’s very transparent motivation has been to delay paying the money they obviously owe our client.  They have sought to use the legal system to achieve this delay, but they have now lost before juries, arbitrators and appellate judges,” said Simon Bloom, who led the Bloom Parham team on the arbitration and appeal. “The real losers in these cases are the victims of the appellant’s malfeasance, who are forced to spend their hard-earned savings pursuing justice, and the civil justice system that has much more important things to do than knock down the latest frolic to come from the appellant and its lawyers.”

— Simon H. Bloom

Background

Univabs, an India-based company, provided radiology services to TRG, a Georgia limited liability company, for more than a decade before a payment dispute arose and Univabs demanded arbitration. TRG countered that one of its own managers, who also held an ownership interest in Univabs, had used that dual role to cause TRG to overpay for Univabs’ services. The arbitrator rejected TRG’s counterclaims and ruled in Univabs’ favor. Univabs then asked the U.S. District Court for the Northern District of Georgia to confirm the award, and TRG moved to vacate it. The district court held that the Federal Arbitration Act governed the dispute and confirmed the award, and TRG appealed to the Eleventh Circuit.

What the Eleventh Circuit Held

The Federal Arbitration Act, not Georgia law, governed the dispute. The court held that a generic Georgia choice-of-law clause was not enough to displace the Federal Arbitration Act, since the parties had agreed to arbitrate under the American Arbitration Association’s rules rather than Georgia’s own arbitration rules.

The arbitrator interpreted, rather than modified, the operating agreement. Applying the same narrow standard of review the Eleventh Circuit set out in its own 2017 decision in Bamberger Rosenheim, Ltd. v. OA Development, Inc., 862 F.3d 1284 (11th Cir. 2017), a case Bloom Parham’s Simon Bloom argued and won for the firm’s client nearly a decade earlier, the court found that the arbitrator had properly construed the agreement’s text and the parties’ intent, rather than rewriting their bargain, and so did not exceed his authority under 9 U.S.C. § 10(a)(4).

Having rejected both of TRG’s arguments, the Eleventh Circuit affirmed the district court’s confirmation of the arbitration award in Univabs’ favor.

Why This Result Matters

For parties to a commercial arbitration agreement, this decision is a reminder that a generic choice-of-law clause naming Georgia law will rarely be enough, on its own, to displace the Federal Arbitration Act. It also confirms how heavily courts defer to an arbitrator’s reading of a contract’s text, even when the losing party believes that reading was wrong. For Univabs, the ruling brings years of litigation over the parties’ business relationship to a close on favorable terms.

Simon H. Bloom led the appeal on behalf of Univabs, joined by Kurt Kastorf and Pierce Ostwalt of the firm’s appellate team.

Facing an Arbitration or Appellate Challenge? Talk to Bloom Parham

Bloom Parham’s appellate lawyers step into high-stakes arbitration and appellate disputes at every level of the Georgia and federal courts, including the United States Court of Appeals for the Eleventh Circuit, where the firm has repeatedly secured confirmation of arbitration awards for its clients. To discuss an arbitration, contract, or appellate matter, reach out to Simon H. Bloom, Kurt Kastorf, or Pierce Ostwalt, or learn more about our appellate litigation practice.