These cases can be read to provide a blueprint for an enforceable arbitration agreement and class action waiver in the ARL context. Arbitration clauses and class action waivers can be a possible solution.A forced arbitration agreement in which employees waived their right to participate in collective legal claims constituted an unfair labor practice. Martorello asserts that the prospective waiver doctrine only applies to arbitration agreements and cannot be extended to any other agreement. Courts around the country continue to approach the enforceability of classaction waivers and arbitration provisions in ERISA plan documents differently.