Garcia’s argument stumbles at the starting gate because he does not explain how Rule 23 conflicts with the “more lenient” standard he proposes under Massachusetts law. Garcia suggests that Rule 23 might interfere with his substantive right to proceed as a class. But he does not explain how a class certification analysis under Massachusetts law would proceed any differently from a Rule 23 analysis. See United States v. Zannino, 895 F.2d 1, 17 (1st Cir.1990) (“It is not enough merely to mention a possible argument in the most skeletal way, leaving the court to do counsel’s work, create the ossature for the argument, and put flesh on its bones.”). Nor do the cases cited by Garcia shed any light on what a “more lenient” standard would look like here. See Machado, 989 N.E.2d at 470 (<HOLDING>); Sebago v. Tutunjian, 85 Mass. App.Ct. 1119, 7
holding that the federal arbitration act requires piecemeal resolution when necessary to give effect to an arbitration agreement and mandates enforcement of an arbitration agreement notwithstanding the presence of other persons who are parties to the underlying dispute but not to the arbitration agreement emphasis added holding that the federal arbitration act requires enforcement of class action waivers in arbitration clauses even when massachusetts law provides for a substantive right to bring a class proceeding holding that the district court did not err by compelling individual rather than class arbitration because the relevant agreements were silent as to class arbitration holding that rookerfeldman precludes jurisdiction over a federal lawsuit to compel arbitration under the federal arbitration act because the action was inextricably intertwined with the plaintiffs failed statelaw action to compel arbitration under the louisiana arbitration act holding that an aaa arbitration was a private proceeding and therefore that a decision by the arbitrator pursuant to the federal arbitration act did not constitute state action