Wis. 2d 304, 311, 471 N.W.2d 263 (Ct. App. 1991) (citing Dehnart v. Waukesha Brewing Co., 21 Wis. 2d 583, 589, 124 N.W.2d 664 (1963), regarding claim preclusion (res judicata) and arbitration awards). 59 Courts have struck down arbitration provisions precluding class representation. See cases cited at 1 Farnsworth, supra note 19, § 4.28, at 593 n.52. 60 Wis. Stat. § 426.110(4)(e). 61 Many other courts have found unconscionable express prohibitions on class actions claims. See, e.g., Ting, 319 F.3d at 1150 (under California law, class action ban in contract of adhesion unconscionable); Comb v. PayPal, Inc., 218 F. Supp. 2d 1165, 1175-76 (N.D. Cal. 2002) (express prohibition on "consolidation of claims" in arbitration agreement unconscionable under California law 9, 894 (9th Cir. 2002) (<HOLDING>); Shankle v. B-G Maint. Mgmt. of Colorado,
holding that an arbitration provision that waived class actions and thus required the consumer to pay a 125 fee to vindicate a 150 claim was substantively unconscionable but also holding that the waiver provision was severable from the remainder of the arbitration provision which would be enforced holding that where the arbitration agreement was silent on feesplitting and the costs imposed upon the plaintiff by the aaa were not prohibitive the plaintiff had presented little evidence to indicate that arbitration would be prohibitively expensive and the fees and costs of arbitration did not render the arbitration scheme unconscionable holding fee splitting provision of arbitration agreement unconscionable under california law 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 fee allocating scheme in an employment contract would alone render the arbitration provision unconscionable under california law