clauses - since the rule was invalidating a large proportion of arbitration agreements, the rule must violate the policy in favor of arbitration. Therefore, it was preempted by the FAA. Justice Stephen Breyer dissented, joined by Justices Ruth Bader Ginsburg, Sonia Sotomayor, and Elena Kagan. Breyer stated that class arbitrations are appropriate ways to resolve claims that are minor individually but significant in the aggregate. "Where does the majority get its contrary idea — that individual, rather than class, arbitration is a fundamental attribute of arbitration?" He said that without class actions, minor frauds would not be remedied. "What rational lawyer would have signed on to represent the Concepcions in litigation for the possibility of fees stemming from a $30.22 claim?" Significance Concepcion has been widely criticized in academic literature, and calls for its reversal through an Arbitration Fairness Act have been made. Following Concepcion, many businesses introduced or renewed motions to move pending lawsuits to arbitration. In September 2011, J. Russell Jackson described the Supreme Court's ruling in Concepcion as "the decision that has launched a thousand motions", as defendants sought to compel arbitration of cases that had been pending "for some time", especially in California. In April 2012, Public Citizen published a list of 76 putative class actions where a court cited Concepcion in granting a motion to compel individual arbitration. University of Kansas law professor Christopher Drahozal wrote that the Public Citizen statistic overstated the impact of Concepcion, as several decisions applied state law that permitted class action waivers prior to Concepcion. Cardozo law professor Myriam Gilles wrote that the Concepcion decision had a greater impact on class actions than Wal-Mart v. Dukes, since Concepcion allowed businesses to avoid class actions by including arbitration clauses in boilerplate terms. The Concepcion decision also impacted the usage of arbitration clauses in consumer contracts, including the usage of "consumer-friendly" arbitration terms like the ones in AT&T's agreement. Jean Sternlight said that the Concepcion decision would cause businesses to include arbitration clauses with class action waivers, saying that the Concepcion decision removed the possibility of "costly litigation" over whether such terms are enforceable. In a 2012 research paper, Gilles wrote that the majority opinion in Concepcion led to a "race to the top" in implementing arbitration procedures that are more friendly to consumer claims and more likely to allow their vindication. Gilles wrote that corporate lawyers encouraged companies to implement terms