Because Wallrich is one of the first appellate cases to address the growing trend of mass arbitration, it is an important case to watch for any company that has, or is considering, adopting arbitration terms in its consumer-facing terms. Mass arbitrations have increasingly emerged as the plaintiff's weapon of choice following the widespread adoption of arbitration provisions with a class action waiver in the wake of the U.S. Supreme Court's decision in AT&T Mobility LLC v. Concepcion, 563 U.S. 333 (2011). In mass arbitration proceedings, arbitration bodies like the AAA usually require the respondent company (not the consumer) to pay most of the initial filing fees. If there are thousands of claimants, these initial fees can amount to millions of dollars, which must be paid before any arbitrator has a chance to assess the validity of the claims. The plaintiffs' bar then uses these sizeable upfront costs to pressure companies into early settlement.