Lamps Plus firmly rejects lower courts' attempts to read Stolt-Nielson narrowly. The Ninth Circuit was not alone in reading that case as limited to its facts. The First Circuit also, in Fantastic Sams Franchise Corp. v. FSRO Assoc., had concluded that Stolt-Nielsen did not require "express contractual language evincing the parties' intent to permit class or collective arbitration." The First Circuit's narrow view of Stolt-Nielsen, along with that of the Ninth Circuit, has now been expressly repudiated by the Supreme Court.