On September 22nd, the Eleventh Circuit affirmed the trial court's denial of an auditor's motion to compel arbitration. Plaintiff, a third party who intended to rely upon the audit, sued the auditor for negligence, among other things. Because the arbitration provision in the auditor's engagement letter with its client was party specific, the court held that the auditor could not compel arbitration with the plaintiff. Corporate America Credit Union v. Herbst.