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In 1925, Congress enacted the Federal Arbitration Act, 9 U.S.C. Sections 1-16 (2012), and in the space of 16 sparsely worded sections covering a few pages forever changed the contractual dispute resolution process in the United States. Congress intended the FAA to counteract judicial hostility to the private dispute resolution regime by validating the enforceability of agreements requiring private arbitration of certain disputes that parties otherwise would have litigated in courts, see American Express v. Italian Colors Restaurant, 570 U.S. 228, 232 (2013); AT&T Mobility v. Concepcion, 563 U.S. 333, 339 (2011); Hall St. Associates v. Mattel, 552 U.S. 576, 581 (2008) and Allied-Bruce Terminix v. Dobson, 513 U.S. 265, 270 (1995).

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