In Maizes, the Eleventh Circuit followed the reasoning in Terminix International Co. v. Plamer Rach Ltd. Partnership [12] and concluded that "the agreement's choice of American Arbitration Association rules, standing alone, is clear and unmistakable evidence that Spirit intended that the arbitrator decide th[e] question" of class arbitrability. [13] The Ray court concluded that the Tenth Circuit's "holding in Belnap ( v. Iasis Healthcare [14]) is instructive," such that "when contracting parties incorporate the AAA rules into a broad arbitration agreement, … such an incorporation clearly and unmistakably evinces their intent to arbitrate arbitrability." [15] The courts also found support for their holdings in the state contract law applicable to each case. [16] Both courts also noted that other circuits—namely the Third, Fourth, Sixth, and Eighth—have come to the opposite conclusion.