LOS ANGELES - A class action against a satellite TV company alleging that its early termination fees violate California's unfair competition law (UCL) and other laws cannot be resolved through arbitration because the arbitration provision in the company's customer agreement contains a class action waiver that is not enforceable under California law, a state appeals court held April 7 (Amy Imburgia, et al. v. DIRECTV, Inc., No. B239361, Calif. App., 2nd Dist., Div. 1).