On September 12, 2012, the California Supreme Court granted review in Iskanian v. CLS Transportation Los Angeles, LLC, in which the trial court compelled arbitration of an employee's wage and hour claims and dismissed his class and representative claims, and the appellate court affirmed the ruling. The parties' agreement provided that "any and all claims" arising out of the employee's employment would be subject to mandatory, binding arbitration and expressly waived each party's right to bring representative and class claims. The appellate court's key holdings are summarized in our June 2012 FEB. Two of the issues identified for likely review focus on arbitration: Whether the U.S. Supreme Court's holding in AT&T Mobility v. Concepcion (Fenwick's April 28, 2011 Litigation Alert) impliedly overruled Gentry v. Superior Court (September 2007 FEB) regarding contractual class action waivers in the context of non-waivable labor law rights, and whether the Concepcion decision permits parties to waive, through an arbitration agreement, the right to bring representatives claims under the California Labor Code Private Attorneys General Act of 2004.