In Mastrobuono v. Shearson Lehman Hutton, Inc. (1995) 514 U.S. 52, Antonio Mastrobuono pressed an arbitration claim against Shearson, his securities broker-dealer, and won an arbitration award that included punitive damages. Invoking a New York choice of law clause in its standard form customer arbitration agreement, Shearson sought to vacate the punitive damages element of the award on the ground that New York law does not permit punitive damages in arbitration. (Id. at pp. 54-55.) Because Mastrobuono had a right to seek punitive damages under the FAA, the United States Supreme Court upheld the award in its entirety. (514 U.S. at pp. 55, 58, 61, 64.) The Supreme Court refused to permit contractual displacement of Mastrobuono's right to punitive damages under a choice of law clause he likely never saw and would not have understood even if he had seen it. The court explained that, at best, "respondents drafted an ambiguous document, and they cannot now claim the benefit of the doubt. The reason for this rule is to protect the party who did not choose the language from an unintended or unfair result. That rationale is well suited to the facts of this case. As a practical matter, it seems unlikely that petitioners were actually aware of New York's bifurcated approach to punitive damages, or that they had any idea that by signing a standard-form agreement to arbitrate disputes they might be giving up an important substantive right. In the face of such doubt, we are unwilling to impute this intent to petitioners." (Mastrobuono, supra, 514 U.S. at p. 63.) In Mastrobuono v. Shearson Lehman Hutton, Inc., the arbitration agreement, a standard form client agreement, provided that it was to be governed by New York law, but that "any controversy arising out of or related to" the agreement was to be settled by arbitration according to the NASD rules "[u]nless unenforceable due to federal or state law." (Id. at 59 n 2) The NASD permitted punitive damage awards by arbitrators. Id. at 61.) The Mastrobuono court noted that the Federal Arbitration Act (FAA) governed the dispute. (Id. at 57.) It further observed that the FAA's proarbitration policy required that private arbitration agreements be "enforced according to their terms," specifically stressing: "Arbitration under the Act is a matter of consent, not coercion, and parties are generally free to structure their arbitration agreements as they see fit. Just as they may limit by contract the issues which they will arbitrate, so too may they specify by contract the rules under which that arbitration will be conducted." (Id. at 57 [internal quotation marks and; see HSBC Bank USA v. National Equity Corp., 279 A.D.2d 251, 254, 719 N.Y.S.2d 20 [1st Dept 2001] [arbitration matter of consent and parties free to structure arbitration agreement as they see fit].) In Mastrobuono, the Court found the contract ambiguous, but alluded to the FAA's policy of favoring arbitration and resolving any doubts as to the scope of arbitration in favor of such arbitration. (Id. at 62.) It, then, utilized rules of contract interpretation in construing the ambiguous agreement. (Mastrobuono, supra at 62-63.) The Court interpreted the contract to require New York law to control substantive principles "but not to include special rules limiting the authority of arbitrators," thereby, permitting the punitive damage award to stand. (Id. at 64.)