Whether arbitration agreements with individual employees that bar them from pursuing
work-related claims on a collective or class basis in any forum are prohibited as an unfair labor
practice under 29 U.S.C. 158(a)(1), because they limit the employees' right under the National
Labor Relations Act to engage in "concerted activities" in pursuit of their "mutual aid or
protection," 29 U.S.C. 157, and are therefore unenforceable under the saving clause of the
Federal Arbitration Act, 9 U.S.C. 2.
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