Q: In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.
Arbitrator manifestly disregarded the law in reaching h'er final decision. See Pl. Mot. at 20 n.16. She does so only in a footnote, however, and never affirmatively argues that "manifest disregard" is still a proper ground for vacatur in light of recent Supreme Court decisions. Id.; see also ARMA, S.R.O. v. BAE Sys. Overseas, Inc., 961 F.Supp.2d 245, 268 (D.D.C. 2013) (discussing Supreme Court's equivocation in Hall Street Associates, 552 U.S. at 585, 128 S.Ct. 1396, on whether manifest disregard of law can be basis for vacatur of arbitral award). The Court thus considers the issue forfeited. Huntington v. Dep't of Commerce, 234 F.Supp.3d 94, 101, 2017 WL 211301, at *4 (D.D.C. Jan. 18, 2017); Gold Reserve Inc. v. Bolivarian Republic of Venezuela, 146 F.Supp.3d 112, 126-27 (D.D.C. 2015) (<HOLDING>); see Hutchins v. District of Columbia, 188
Holding statements: (A) holding that the validity of a collateral waiver is a threshold issue (B) holding that the waiver in two previous contracts was insufficient to support waiver of the contract at issue in that appeal (C) holding that failure to raise issue at district court forecloses party from raising same issue on appeal (D) holding obliquely raising issue in footnote insufficient to surmount waiver threshold (E) holding that an argument raised only in a footnote of a brief is waived
A:
holding that the validity of a collateral waiver is a threshold issue