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It is a truism of arbitration law that arbitration is a creature of party choice.1 Within broad limits of public policy, parties to contracts can choose whether to arbitrate, what to arbitrate and how to arbitrate their disputes.2 In the United States that policy is expressed in the Federal Arbitration Act (FAA),3 which has been interpreted to uphold agreements to arbitrate according to the terms agreed by the contracting parties.4

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