Any = Any

The parties’ agreement said: “Upon payment of the Lease Termination Fee, TTE will not longer have any obligations under Section 9.1A.”  The district court found that the structure of the agreement meant that provision did not apply to all of the relevant buildings.  The Fifth Circuit disagreed: “While such a divisions may be analytically satisfying, it is unsupported by any other language in the MOU, such as, for example, a paragraph heading identifying a particular provision as only relating to one warehouse.”  APL Logistics Americas, Ltd. v. TTE Technology, Inc., No. 13-10352 (Dec. 13, 2013, unpublished).