Does the Federal Arbitration Act allow use of the rules of an arbitral association in the text of a boilerplate, or form, arbitration agreement to prove that the non-drafting party had delegated away to arbitration, all of its rights to judicial determination of the scope of the agreement or other aspects of the arbitrability of all claims between the parties?

QUESTIONS PRESENTED 1. Does the Federal Arbitration Act allow use of the rules of an arbitral association in the text of a boilerplate, or form, arbitration agreement to prove that the non-drafting party had delegated away to arbitration, all of its rights to judicial determination of the scope of the agreement or other aspects of the arbitrability of all claims between the parties? 2. When there is a dispute over the delegation of arbitrability, particularly one arising from a boilerplate arbitration agreement, is a “clear manifestation of intent” by the non-drafting, non-demanding party to be considered by a court as a burden of proof, or is it a legal standard that can be met by the writing in the agreement alone, and which party would have the burden of proof?