Global Client Solutions, LLC v. Ossello

¶52 In my opinion, this case is controlled by Rent-A-Center, West, Inc., v. Jackson, 561 U.S. 63, 130 S. Ct. 2772 (2010), and the requirement that a delegation provision contained within an arbitration clause must *361be specifically challenged as unenforceable. I would further conclude that the specific language of the delegation provision and the DDA’s incorporation of the AAA rules provide “clear and unmistakable” evidence that the question of arbitrability was to be decided by an arbitrator. Finally, while non-mutuality is a defense under state law to a contract, not every degree of…