Over the past decade, proponents of class actions have decidedly been put on the defensive. In a line of cases beginning with AT&T Mobility LLC v. Concepcion, the Supreme Court has held that contractual agreements re­quiring individual arbitration are protected under the Federal Arbitration Act of 1925. 563 U.S. 333, 352 (2011) (overturning a California common law rule that prohib­ited contracts from disallowing class-wide arbitration, finding that such a rule is preempted by the Federal Arbitration Act); see also Epic Sys. Corp. v. Lewis, 138 S. Ct. 1612, 1616 (2018) (upholding employment agreements requiring individual arbitration and dismissing a chal­lenge based on the Federal Arbitration Act's saving clause and the National Labor Relations Act); Am. Express Co. v. Italian Colors Rest., 570 U.S. 228, 228 (2013) (holding that con­tractual agreements requiring individual arbitration cannot be invalidated on the ground that costs of individual arbitration exceed the potential recovery).