Three recent Appellate Division opinions address the issue of whether and how far the consumer-protective requirements of Atalese v. U.S. Legal Servs. Grp., L.P., 219 N.J. 430 (2014), for individual consumers in contracts of adhesion should be applied to agreements between sophisticated business parties to arbitrate. In County of Passaic v. Horizon Healthcare Servs., Inc., 474 N.J. Super. 498 (App. Div.), certif granted, ___N.J.___(2023), the Appellate Division held that sophisticated commercial parties to an arbitration agreement, represented by counsel, reasonably understood the nature of arbitration and, therefore, need not have met the Atalese requirement of an explicit statement that arbitration waived the parties' right to resolve their dispute in a court and/or with a jury.