In an action alleging claims for civil liability under the Federal Racketeer Influenced and Corrupt Organizations (RICO), the District Court held that the proceeding should not be stayed and referred to arbitration because of the arbitration clause in certain trust deeds. While the trust deeds did delegate the issue of “arbitrability” – whether the parties were bound to an arbitration clause – to arbitrators through the incorporation of the rules of the London Court of International Arbitration, neither the plaintiffs nor the defendants were parties to the trust deeds. The Court therefore examine the issue independently and concluded that under the applicable English law, the defendants could not enforce the arbitration clause against the plaintiffs.