On April 24, 2019, in Lamps Plus, Inc. et al. v. Frank Varela, 587 U.S. _ (2019), the U.S. Supreme Court maintained its long-standing position, expressed in its earlier decision in Stolt-Nielsen S.A. v. AnimalFeeds Int’l Corp., 559 U.S. 662 at 684 (2010), that “…a party may not be compelled under the FAA to submit to class arbitration unless there is a contractual basis for concluding that the party agreed to do so.” In Stolt-Nielsen, the Court had held that “silence is not enough”; and in Lamps Plus, the Court further held that courts may not infer consent to class arbitration from an ambiguous agreement. The doctrine of contra proferentem – interpreting an ambiguous agreement against the drafter – “cannot be applied to impose class arbitration in the absence of the parties’ consent.”