In Fridl v. Cook, 908 S.W.2d 507 (Tex. App.--El Paso 1995, writ dism'd w.o.j.), the plaintiff contracted with the defendant to market the defendant's company's products, but thereafter the defendant allegedly diverted the business the plaintiff generated to another one of his companies and thereby avoided paying the plaintiff his commissions. Id. at 509-14. The arbitration clause in that case encompassed "any and all controversies, disputes or claims arising out of or relating to this Agreement or a breach thereof." Id. at 509. The court wrote that the alleged fraud claim was not linked to any contractual breach because the defendant and the defendant's company with which the plaintiff contracted could have honored their contractual obligations "in every respect" and yet been liable for fraudulently inducing the plaintiff to obtain business for a business outside the contract, so the court ruled the claim arose outside the contract. Id. at 513.