1. Dissenting Opinion of Justice C�t�, at para. 222. Uber Technologies Inc. v. Heller, 2020 SCC 16, Dissenting Opinion of Justice C�t�, at para. 221 (an arbitration clause "is ancillary or collateral to the underlying contract and should be considered as "autonomous and juridically independent from the main contract in which it is;SCC,2020
2. ) (an arbitration contract "is often to be found as an arbitration clause in a commercial, industrial, or other type of contract. Where so found it is, in strict analysis, a separate contract, ancillary to the main contract"). On the separability doctrine generally, see;Am. Rev. Int'l Arb,2003