David A. Ruben, J.D. candidate, Penn State Dickinson School of Law (2005); B.A. Economics, cum laude, Vanderbilt University (2000). Mr. Ruben would like to thank his father for inspiring this Comment. Mr. Ruben is a Managing Editor of The Journal of American Arbitration and had previously published his Case Note in issue 2:2 of the Journal entitled, “Schoch v. info USA, Inc.: The Eighth Circuit Recognizes Contractual Expansion of Judicial Review in Arbitration Agreement.”