( January 15, 2026, 9:53 AM EST) -- NEW YORK — Writing that “it would be difficult to imagine a breach-of-contract claim that did not arise out of the contract itself,” a New York federal judge compelled arbitration and stayed litigation between a program manager and an insurer, holding that the parties’ terminated program management agreement (PMA) required arbitration of claims alleging years of underpaid commissions and was not displaced by the agreement’s termination or survival provisions....