sufficient consideration. So although the Ohio courts do not appear to have addressed this issue, we adopt a position that is consistent with their decisions and endorsed by the Restatement. See also Harmon, 697 N.E.2d at 272 (noting that under Ohio law, “a detriment to the promisee” such as “forbearance ... by the promisee” may constitute consideration). Further, the present case is distinguishable from Floss, in which we concluded that an arbitration agreement was unenforceable because the employer had “unfettered discretion in choosing the nature of [the arbitral] forum” and could alter the applicable rules and procedures without any notice to or consent from employees. Floss, 211 F.3d at 315-16; see also Hooters of Am., Inc. v. Phillips, 173 F.3d 933, 938-40 (4th Cir.1999) (<HOLDING>). Unlike in Floss, in this case Circuit City
holding that an arbitration agreement was invalid because inter alia the employer could modify the rules at any time without notice holding inter alia that common law claims were preempted holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs holding that an arbitration agreement that was invalid due to unconscionability was not enforceable holding that proposed invalidation of the entire arbitration agreement even if the court were convinced that the plaintiff could not afford to pay for the arbitration proceedings was unnecessarily radical because the court could instead simply nullify the fee provisions of the arbitration agreement and force the defendant employer to bear the expense of arbitration