On November 7th, the Supreme Court of the United States vacated a Florida appellate court's order refusing to compel arbitration in a Bernard Madoff feeder fund case. Investors bought partnership interests in KPMG-audited funds which invested with Madoff. The investors allege KPMG failed to use proper auditing standards in reviewing the funds' financial statements, violating common and statutory law. The Supreme Court held that any arbitrable claim must be sent to arbitration. Because the state court only addressed two of the four claims when it refused to compel arbitration, its order must be vacated for reconsideration of the other two claims. KPMG LLP v. Cocchi (per curiam).