transaction or a contract evidencing a transaction involving commerce to settle by arbitration a controversy thereafter arising out of such contract or transaction ... shall be valid, irrevocable, and enforceable, save upon such grounds as exist at law or in equity for the revocation of any contract.’ " (quoting 9 U.S.C. § 2)). 30 . Id. at 339-40, 131 S.Ct. 1740 (citations omitted). That arbitration agreements are instruments of a fraudulent scheme is not an arbitration-specific defense. Any contract employed as an instrument of a fraudulent scheme would similarly be invalid. In any event, the cases cited by the Court evidence its concern for state laws targeting arbitration clauses. E.g., Doctor's Associates, Inc. v. Casarotto, 517 U.S. 681, 683, 116 S.Ct. 1652, 134 L.Ed.2d 902 (1996) (<HOLDING>). 31 . — U.S.-, 133 S.Ct. 2304, 186 L.Ed.2d 417
holding that state law governs whether an arbitration clause is enforceable against a nonsignatory under the faa holding that all arbitration provisions dealing with transactions involving interstate commerce are subject to the faa holding that whether in federal or state court a challenge to the validity of the contract as a whole and not specifically to the arbitration clause within it must go to the arbitrator and not the court recognizing a liberal federal policy favoring arbitration in the faa holding that montanas firstpage notice requirement which governs not any contract but specifically and solely contracts subject to arbitration conflicts with the faa and is therefore displaced by the federal measure