On January 17, 2014, an administrative law judge (ALJ) for the National Labor Relations Board (NLRB) held that maintaining and enforcing a mandatory arbitration agreement violated the National Labor Relations Act (NLRA) by interfering with an employee's Section 7 right to engage in concerted activity, even though the agreement did not expressly prohibit classwide, collective or representative actions. Leslie's Poolmart, Inc. v. Keith Cunningham, No. 21-CA-102332, 2014 WL 204208 (N.L.R.B. Jan. 17, 2014). In so holding, the ALJ expanded the NLRB's controversial decision in D.R. Horton, Inc., 357 N.L.R.B. No. 184 (Jan. 3, 2012), where the NLRB held that an arbitration agreement violated the NLRA because it explicitly precluded the filing of joint, class or collective actions...