CONTRACTS.” Uber’s January 4, 2016 driver service agreement
with the appellant is 14 pages. The November 29, 2016 UberEATS
service agreement with the appellant is 15 pages.
 Uber determines the maximum fares drivers receive for
their work according to a base fare amount plus distance (based
on GPS data obtained through the app), plus applicable time
amounts. Uber collects the fares from customers, provides customers with a receipt and remits payment periodically to drivers,
less Uber’s fees.
 Drivers can report complaints to Uber through the apps.
Customer service representatives (“CSRs”) in the Philippines
first receive the complaints. If unresolved, they escalate the complaints to CSRs in Chicago, then to Uber’s legal team. Drivers
may also attend in Ontario at an Uber “Greenlight Hub”, which
is a support centre staffed with Uber employees, to ask for assistance, although the appellant says that the staff there will likely
only refer the driver back to the app for assistance.
 The appellant entered into a driver services agreement
with Rasier Operations B.V. on June 7, 2016, and an UberEATS
services agreement on December 15, 2016. Each agreement con-
tains the following arbitration clause (the “Arbitration Clause”):
Governing Law; Arbitration. Except as otherwise set forth in this Agreement,
this Agreement shall be exclusively governed by and construed in accordance
with the laws of The Netherlands, excluding its rules on conflicts of laws . . . Any
dispute, conflict or controversy howsoever arising out of or broadly in connec-
tion with or relating to this Agreement, including those relating to its validity,
its construction or its enforceability, shall be first mandatorily submitted to
mediation proceedings under the International Chamber of Commerce Medi-
ation Rules (“ICC Mediation Rules”). If such dispute has not been settled
within sixty (60) days after a request for mediation has been submitted under
such ICC Mediation Rules, such dispute can be referred to and shall be exclu-
sively and finally resolved by arbitration under the Rules of Arbitration of the
International Chamber of Commerce (“ICC Arbitration Rules”) . . . The dis-
pute shall be resolved by one (1) arbitrator appointed in accordance with ICC
Rules. The place of arbitration shall be Amsterdam, The Netherlands . . .
 Under the ICC Mediation Rules, drivers must pay
a US$2,000 non-refundable filing fee to initiate mediation proceedings against Uber. For disputes valued under US$200,000,
drivers must pay an additional administrative fee, which may be
as much as US$5,000. These fees do not cover the mediator’s fees
or legal fees.
 If the parties are unable to resolve their dispute through
mediation within 60 days, they must proceed to arbitration under
the ICC Arbitration Rules. A driver, and any party wishing to join
the arbitration, must each pay a US$5,000 filing fee.
 Article 37 of the ICC Arbitration Rules requires the parties
to pay an advance on costs “in an amount likely to cover the fees