Mass arbitration has become a potent weapon in consumer privacy litigation. In one recent case involving claims under the Illinois Biometric Information Privacy Act (BIPA), Samsung turned the tables on the claimants, who likely were counting on leveraging the applicable American Arbitration Association (AAA) filing fee, by refusing to pay the fee, prompting the AAA to terminate the arbitration. The case ended up before the U.S. Court of Appeals for the Seventh Circuit (Court), which found that claimants had not established the existence of a binding arbitration agreement, and, even if they had, the arbitration had already been completed in accordance with AAA rules. The first article in our two-part coverage of the case examined the Court’s analysis and discussed relevant procedural background. In the second article, Baker Donelson biometrics team lead David Oberly addressed the key takeaways and practical implications of the decision, provided strategies for strengthening arbitration agreements and discussed the future trajectory of mass arbitration tactics in BIPA class action litigation.