The Ninth Circuit has continued to chip away at California’s McGill rule, which bars the enforcement of arbitration provisions that waive a plaintiff’s right to seek public injunctive relief in any forum. In Cottrell v. AT&T Inc., 2021 WL 4963246 (9th Cir. Oct. 26, 2021), the court extended its earlier decision in Hodges v. Comcast Cable Commc’ns, LLC, — F.4th –, 2021 WL 6110309 (9th Cir. Sept. 10, 2021), to hold that the injunctive relief sought by plaintiff—practices that would prevent AT&T from improperly charging accounts in the future—would benefit only AT&T customers. Because this relief would not be “for the benefit of the general public” under Hodges, the lawsuit did not seek public injunctive relief, and the Ninth Circuit reversed the district court’s denial of defendant’s motion to compel arbitration. Hodges and Cottrell therefore provide a clear roadmap for defendants seeking to overcome most McGill challenges to arbitration agreements.