HR dept emails NEW arbitration requirement buried in bottom of text of long email; policy merely attached. Fired employee; He responds with ADA claim. Employer tries to dismiss based on arbitration required by email. Proved he opened the email. COULDN'T prove he read it/attachment. Employee convinced Fed appeals court to strike the policy - judges found email bland, didnt clearly announce loss of right to sue - buried at the bottom. Also: certain HR waivers must signed in writing.