similar to the ones used by AT&T Mobility and upheld in Concepcion. According to Gilles, many large consumer-oriented businesses changed their arbitration provisions in 2011 and 2012. However, Gilles noted that only 6 out of the 37 companies she examined had arbitration clauses that "offered anything close to AT&T's set of incentives, and none were quite as generous". Ann Marie Tracey and Shelley McGill wrote that businesses would introduce more consumer-unfriendly terms in their arbitration clauses since unconscionability "provided strong motivation for business to draft agreements fairly in the pre-Concepcion environment; that motivation does not exist in the post-Concepcion era." Suzanna Sherry said that the broad holding of the decision would make harsh arbitration clauses, similar to the earliest consumer arbitration clauses, enforceable, since the unconscionability doctrine that had been used to strike down those harsh clauses could be found preempted based on Concepcion. Several large businesses introduced arbitration provisions after Concepcion, and several companies' addition of arbitration clauses was reported by the media to have been prompted by the Supreme Court's ruling in Concepcion. According to a September 2011 CNN article, a Sony spokesperson said that Sony added an arbitration clause to its PlayStation Network terms of service because "[t]he Supreme Court recently ruled in the AT&T case that language like this is enforceable". PCWorld writer Jared Newman cited Sony and Microsoft as examples of companies that took advantage of Concepcion to add arbitration agreements with class action waivers. Drahozal and University of Georgia law professor Peter B. Rutledge wrote that Sony and Netflix added arbitration provisions following data breach class action litigation. Other companies reported to have added arbitration provisions to their consumer contracts after Concepcion include Umpqua Bank, Valve, eBay, PayPal, Instagram, and StubHub. American Arbitration Association Senior Vice President Richard Naimark said that a number of companies increased their usage of consumer arbitration after Concepcion, while before Concepcion, the number of consumer arbitrations administered by the AAA had been declining. Rutledge and Drahozal wrote that the adoption of arbitration in franchise contracts did not significantly increase after Concepcion or Am. Express Co. v. Italian Colors Rest., a case decided in 2013 that closely followed Concepcion, casting doubt on the hypothesis that Concepcion would cause businesses to adopt arbitration en masse. In November 2015, Stephen L. Carter wrote that although he and other critics had predicted that businesses would introduce "increasingly burdensome and one-sided arbitration clauses", "this