Delaware forum selection clauses cannot apply to "rights or relationships" not created by Delaware law

Francis Pileggi throughly analyzes the important new Sciabacucchi v. Salzberg decision, in which "the Court determined that a forum-selection clause in a certificate of incorporation was invalid and ineffective to the extent that it purported to 'require any claim under the Securities Act of 1933 to be brought in federal court' (the 'Federal Forum Provisions')."