[brief] PRIMERICA IMPROPERLY ASSERTS THAT PRIMERICA’S SAM ACCOUNT REGISTRATION PROVIDED NOTICE OF THE ARBITRATION AGREEMENT  [...] attempts to raise an argument not properly presented to the motion court below as it was only raised in reply.  This Court, like the trial court, need not consider this matter as it was improperly raised.  *Nieder v. Royal Indem. Ins. Co.*, 62 N.J. 229, 234 (1973); Pressler & Verniero, *Current N.J. Court Rules*, cmt. 3 on *R.* 2:6-2 (2022); *Berlin*, 337 N.J.  Super. at 596 (App. Div. 2001) (“Raising an issue for the first time in a reply brief is improper. ”).  Because [...]’s moving submission improperly relied on the certification of its counsel, in violation of *Rule* 1:6-6, rather than an individual who has knowledge of the alleged arbitration agreement (such as [...]), it attempted to remedy this deficiency through a certification from [...]’s COO, [...].  Through that certification, however, [...] did not simply authenticate the records it submitted in connection with its moving submission, it sought to expand the scope of its arguments to include new theories that were not argued in its moving papers.  These new arguments were submitted on January 26, 2024, 79 days after its moving brief was filed and just five days before the return date of the Motion to Compel.  Regardless of the gamesmanship, the [...] certification likewise was replete with opinion, hearsay, and speculation, and was wholly unsubstantiated by [...]’s “business records” (including screenshots from the “Wayback machine,” which presumably are not maintained by [...] in the ordinary course of its business).  Here, as they did below, [...] seeks to incorporate “facts” about the Plaintiffs’ registration of an online account and general information about actions allegedly taken by the Plaintiffs that [...] and [...] have no way of knowing.  Because [...] could not refute that Plaintiffs reviewed or executed the Arbitration Agreement, [...] improperly presented the theory that because someone registered an account on [...]’s website using the Plaintiffs’ personal identifying information, Plaintiffs somehow viewed, read, understood, and assented to the Terms and Conditions contained in a browsewrap agreement, which resulted in Plaintiffs waiving their rights and agreeing to arbitrate claims – even if those claims accrued before the website was accessed.  As set forth in Section I, supra, [...]’s Point IV should only be considered if it meets the plain error standard under Rule 2:10-2.  “Relief under the plain error rule, R. 2:10-2, at least in civil cases, is discretionary and ‘should be sparingly employed. ’”  Baker v. Nat’l State Bank, 161 N.J. 220, 226 (1999) (quoting Ford v. Reichert, 23 N.J. 429, 435 (1957)).  Here, even if the Court were to consider [...]’s untimely argument, there was no error by the trial court because the [...] certification and exhibits submitted by [...] for the first time on reply, still do not provide any evidence that the Plaintiffs personally took any action that demonstrates their assent to arbitrate their claims against [...] or any other Defendant.  For these reasons, and those set forth in Point Four below, [...]’s reliance on the browsewrap agreement in its website is unavailing.