We previously wrote about a Ninth Circuit appeal taken by Verizon Wireless, Inc. after a California district court judge held that its arbitration agreement, which required mass arbitration disputes to be resolved by multiple rounds of bellwether arbitrations, was substantively unconscionable because it effectively eliminated the claims of thousands of Verizon customers who were required to wait for up to 156 years for the bellwether arbitrations to conclude. It has now been reported that the Verizon litigation has been settled, and the Ninth Circuit docket reflects that the appeal is being held in abeyance pending final court approval of the settlement. Accordingly, the Verizon appeal will not provide much needed appellate guidance on the use of batching and bellwether procedures to resolve mass arbitration demands. While that window has closed, another one has opened.