In the second California appellate decision to address class action waivers in employment arbitration agreements since the U.S. Supreme Court's ruling in AT&T Mobility LLC v. Concepcion (see the April 2011 Litigation Alert) upholding the enforceability of class action waivers in arbitration agreements, the court refused to enforce an arbitration agreement due to its purported waiver of representative actions under California's Private Attorneys General Act ("PAGA"). See Urbino v. Orkin Services of California, Inc. Following the reasoning of Brown v. Ralphs Grocery Co. (see the August 2011 FEB), the court determined such waivers contradict "the fundamental purpose of a representative enforcement action under PAGA" and are therefore "unconscionable and unenforceable." Consequently, the court refused to extend the AT&T Mobility holding to PAGA representative actions. Many employment law practitioners question the viability of the Urbino and Ralphs Grocery decisions in light of the U.S. Supreme Court's AT&T Mobility broad ruling and await further direction as case law continues to develop in this area.