With no explanation, chose the best option from "A", "B", "C" or "D". sufficient consideration. So although the Ohio courts do not appear to have addressed this issue, we adopt a position that is consistent with their decisions and endorsed by the Restatement. See also Harmon, 697 N.E.2d at 272 (noting that under Ohio law, “a detriment to the promisee” such as “forbearance ... by the promisee” may constitute consideration). Further, the present case is distinguishable from Floss, in which we concluded that an arbitration agreement was unenforceable because the employer had “unfettered discretion in choosing the nature of [the arbitral] forum” and could alter the applicable rules and procedures without any notice to or consent from employees. Floss, 211 F.3d at 315-16; see also Hooters of Am., Inc. v. Phillips, 173 F.3d 933, 938-40 (4th Cir.1999) (<HOLDING>). Unlike in Floss, in this case Circuit City

A: holding that an arbitration agreement that was invalid due to unconscionability was not enforceable
B: holding inter alia that common law claims were preempted
C: holding that an arbitration agreement was invalid because inter alia the employer could modify the rules at any time without notice
D: holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs
C.