31 pages. "Here, where the plan at issue undisputedly contains an arbitration provision and the dispute fits squarely within its scope, ... the District Court erroneously invalidated the arbitration provision ... In so holding, the District Court failed to harmonize and give effect to the FAA and ERISA, contrary to both statutes' language and Supreme Court precedent. The consequence of this failure is the handcuffing of plan sponsors' ability to resolve plan-related claims efficiently and cost-effectively in arbitration, creating a powerful disincentive for plan sponsors to establish and maintain plans in the first place." [Smith v. Board of Directors of Triad MA, No. 20-2350 (N.D. Ill. Aug. 21, 2020; on appeal to 7th Cir., No. 20-2708)]