A federal court in New York held that it lacked federal diversity jurisdiction over an action to confirm a $60,000 arbitration award. In re Doctor’s Associates, Inc. v. Navindra Gharbaran, 2011 U.S. Dist. LEXIS 33693 (S.D.N.Y. Mar. 30, 2011). The franchisor, Doctor’s Associates, Inc., had obtained an award against a former franchisee that included damages of $60,000 and an injunction prohibiting the former franchisee from continuing to operate her restaurant as a Subway franchise. The federal court denied the petition to confirm the award because the amount in controversy did not exceed the federal jurisdictional minimum of $75,000. The court rejected the franchisor’s request to consider the value of the declaratory and injunctive relief, as the court found that the $60,000 award had addressed all damages suffered.