The Ninth Circuit held that an arbitration award did not preclude a plaintiff’s subsequent lawsuit arising out of the same facts because the plaintiff could not have asserted a RICO claim in the arbitration and therefore could not have achieved full satisfaction of its claim there.  Uthe Tech. Corp. v. Aetrium, Inc., 808 F.3d 755 (9th Cir. 2015) (No. 13-16917).  The court held that an additional award of damages under RICO would not violate the “one satisfaction” rule, an equitable principle designed to prevent double recovery of damages arising from the same injury, because the arbitral award did not constitute full satisfaction of the plaintiff’s RICO claim.  The court noted that the original arbitration was brought under Singapore law, which could not provide for resolution of plaintiff’s RICO claim, and therefore plaintiff was not foreclosed from asserting that claim in a subsequent action.