of an arbitration clause is insufficient to enforce the arbitration provision.” Id. at 1550. New York law required mutuality; an arbitration provision was unenforceable unless both parties to the contract exchanged reciprocal promises to arbitrate. Hull’s mutuality requirement, based on New York law, has not been widely accepted. Indeed, New York itself has subsequently overruled its mutuality requirement. See Sablosky v. Edward S. Gordon Co., 73 N.Y.2d 133, 538 N.Y.S.2d 513, 535 N.E.2d 643, 646 (1989) (“mutuality of remedy is not required in arbitration contracts. If there is consideration for the entire agreement that is sufficient; the consideration supports the arbitration option, as it does every other obligation in the agreement”); see also Latifi v. Sousa, 1996 WL 735260 at *5 (<HOLDING>). Latifi also notes Hull’s lackluster reception
recognizing the rule and surveying new york law holding that under new york law a manufacturer is not obligated to design a product that is impossible to abuse recognizing new york law as not imposing a diagnosable and compensable limitation holding that new york law applies to this matter recognizing same and quoting design benefit plans inc v enright 940 fsupp 200 204 ndill1996 as far as new york law is concerned hull is no longer good law