Fourteenth Court Holds Non-Signatory Bound by Forum-Selection Clause Through Incorporation in Alaska JOA Dispute

The Fourteenth Court of Appeals affirmed denial of a special appearance by Cornucopia Oil and Gas, holding that an operator who executed an Amended Joint Operating Agreement governing Alaska's Kitchen Lights Unit was bound by a Texas forum-selection clause in an Assignment it did not sign, where the Amended JOA expressly stated it was "subject to the Assignment" and that "in the event of any conflict between this Agreement and the Assignment, the Assignment Agreement shall control." The dispute arose from allegations that Cornucopia breached carried interest provisions by charging Prohibited Expenses to working interest owners.