On June 20, 2013, the United States Supreme Court issued its decision in American Express Co. v. Italian Colors Restaurant, holding that the Federal Arbitration Act ("FAA") "does not permit courts to invalidate a contractual waiver of class arbitration on the ground that the plaintiff's cost of individually arbitrating a federal statutory claim exceeds the potential recovery." This decision augments the Supreme Court's 2011 decision in AT&T Mobility v. Concepcion, in which the Court held that the overarching purpose of the FAA is to ensure the enforcement of arbitration agreements according to their terms, and when a state law stands as an obstacle to the accomplishment of this objective, it is preempted. Now, with its decision in American Express, the Court has made clear that "arbitration is a matter of contract," and "courts must 'rigorously enforce' arbitration agreements according to their terms" – even if that means low value claims will not be prosecuted.