The U.S. Supreme Court recently denied certiorari in Iskanian v. CLS Transp. Los Angeles, LLC, 59 Cal. 4th 348 (2014), cert. denied (No. 14-341, Jan. 20, 2015), which was discussed in our August 2014 issue. Accordingly, the California Supreme Court's two main holdings in that case stand: The Federal Arbitration Act ("FAA") does not preempt California's public policy prohibiting waivers in employment contracts of representative actions brought under the Labor Code Private Attorney General Act of 2004 ("PAGA"), Cal. Labor Code § 2698 et seq. On the other hand, in private class actions, "a class waiver is not invalid even if an individual proceeding would be an ineffective means to prosecute certain claims . . . because class proceedings interfere with fundamental attributes of arbitration."