In Arellano v. T-Mobile USA, Inc., No. C 10-05663 WHA, 2011 U.S. Dist. LEXIS 41667 (N.D. Cal. May 16, 2011), the court, applying Concepcion, granted a motion to compel arbitration claims for injunctive relief brought under the California Unfair Competition Law, California Consumer Legal Remedies Act, California False Advertising Act, and Federal Communications Act. The plaintiff argued that these claims for injunctive relief were not subject to arbitration because the California Supreme Court previously had held that suits for injunctive relief under those statutes were not subject to arbitration. The court held that Concepcion compels FAA preemption when “state law prohibits outright the arbitration of a particular type of claim” and thus the FAA “preempts California’s exemption of claims for public injunctive relief from arbitration, at least for actions in federal court.” Id. at *4.