A forum selection clause in the parties’ contract was held to supersede a pre-existing arbitration clause contained in the parties’ membership rules.  Goldman, Sachs & Co. v. Golden Empire Sch. Fin. Auth., Nos. 13-797-cv, 13-2247-cv, (2d Cir. Aug. 21, 2014).  The parties’ contract contained a forum selection clause providing that any disputes shall be brought in federal court.  The contract also had a merger clause stating that it contained the entire agreement between the parties relating to the subject matter.  After a dispute arose, one of the parties commenced a FINRA arbitration relying on the other party’s FINRA membership and FINRA rules, which state that a FINRA member must arbitrate a dispute if arbitration is requested by the customer.  The court concluded that the forum selection clause in the parties’ contract requiring all actions and proceedings to be brought in federal court superseded an earlier agreement to arbitrate arising from one party’s FINRA membership.