“cannot ignore the strong policy, made clear in both federal and Maryland law, that favors the enforcement of arbitration provisions.” Id., 386 Md. at 438, 872 A.2d at 751. b. Illusionary promise The plaintiffs also argue that the agreement, by its own terms, cannot take away the right to collective action because the agreement states that both parties would “retain all substantive legal rights and remedies.” Pis.’ Mem. in Op. 24. As discussed above, the plaintiffs argue that the limitation on collective actions restrains a substantive legal right, and thus conflicts with this clause. Id. Any internal inconsistency of the agreement is a matter for the arbitrator to consider. See Moses H. Cone Mem. Hosp. v. Mercury Constr. Corp., 460 U.S. 1, 24, 103 S.Ct. 927, 74 L.Ed.2d 765 (1983) (<HOLDING>). An internal inconsistency does not destroy
holding that in the absence of an agreement to the contrary issues of substantive arbitrability  are for a court to decide and issues of procedural arbitrability ie whether prerequisites such as time limits notice laches estoppel and other conditions precedent to an obligation to arbitrate have been met are for the arbitrators to decide  quoting the revised uniform arbitration act of 2000 ruaa  6c cmt 2 emphasis added and in the original holding that while the determination of the scope of an arbitration agreement is for the court the enforcement of pleading requirements before the arbitrator is a procedural matter for the arbitrator holding that all issues other than arbitrability such as fraud in the inducement are for the arbitrator to decide after a court has determined that the arbitration agreement is valid holding that the trial court not the arbitrator must decide a challenge to an arbitration provision based on public policy holding that the arbitrator is without power to determine arbitrability absent clear  and unmistakable language in the arbitration agreement conferring such power