In Mitri v. Arnel Management Co, the employer attempted to compel arbitration of a sexual harassment lawsuit based upon an arbitration provision in an employee handbook. A California court of appeal refused to compel arbitration where the handbook acknowledgment form only acknowledged that employee "read and understood" the handbook. The court explained that the acknowledgment form lacked any words of "agreement" to arbitrate. Further, the handbook's arbitration provision contemplated a separate, formal arbitration agreement, which did not exist.