After the issue was remanded by the California Supreme Court [118 P.3d 1017] for further consideration in light of Discover Bank v. Superior Court, the First Appellate District, in an unpublished decision, determined that the mandatory arbitration provision precluding class treatment was procedurally unconscionable as the amendment was provided through a bill insert, and was substantively unconscionable as in furtherance of “a scheme to deliberately cheat large numbers of consumers out of individually small sums of money.” Parrish v. Cingular Wireless,No. A105518, 2005 Cal.App.Unpub.LEXIS 9021 (Cal. App. 1st Dist. Oct. 3, 2005), modified, 2005 Cal.App.Unpub.LEXIS 10022 (Cal. App. 1st Dist. Nov. 2, 2005); see also, Discover Bank v. Superior Court (2005) 36 Cal.4th 148, 30 Cal.Rptr.3d 76. [See also: Tamayo v. Brainstorm, No. 02-15724, 2005 U.S. App. LEXIS 20669 (9th Cir. Sept. 21, 2005) (under California law, class-action waivers in arbitration clauses contained in contracts of adhesion are unconscionable).]