In September, the California Supreme Court granted review of Brown v. Superior Court (June 2013 FEB). There, the appellate court concluded that claims under the California Private Attorneys’ General Act of 2004 advance a predominately public purpose and a private arbitration agreement purporting to waive such representative action was unenforceable. The Court deferred briefing pending resolution of Iskanian v. CLS Transportation of Los Angeles (October 2012 FEB), which is expected to address the same and other related issues. In Iskanian, the parties completed briefing in April 2013, followed by briefing of interested third-party groups (amicus curiae) in May and responses thereto in July; as a next step, the matter should be scheduled for hearing.