In consumer law, model contracts often contain mandatory arbitration clauses prior to refusal, which require consumer arbitration. Under these agreements, the consumer may waive his right of recourse and class action. In 2011, one of these clauses was maintained in AT&T Mobility v. Concepcion.  The Tribunal was satisfied that all of these criteria were in place, which meant that the clause was an effective arbitration clause. However, the Tribunal had to determine the importance of the sentence «The two parties decide by mutual agreement to refer any dispute to ..». The defendant argued that this meant that the parties had already reached an agreement or «mutual agreement» and had already decided, through the contract they concluded, to refer to arbitration «any dispute» that might arise between them. In arbitral tribunal jargon, repeaters are parties who often participate in arbitration in order to avoid lawsuits, according to Cole and Blankley. In contrast, one-shot players, often individual consumers, have little experience with refereeing. Although arbitral awards are characteristic of a glimmer of damages against a party, courts in many jurisdictions have a number of remedies that may be part of the arbitral award. .