What is a reasonable statute-of-limitations to write into an arbitration clause?

This author points out that in one recent case 90 days was deemed sufficient, while in another equally recent decision two years was considered by the court to be too sort:

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The two cases are:

Letourneau v. FedEx Ground Package Sys., Inc., No. Civ. 03-530-B, 2004 WL 758231, at *1 (D.N.H. Apr. 7, 2004) (upholding ninety-day limitations period), and

McKee v. AT&T Corp., 191 P.3d 845, 859-60 (Wash. 2008) (invalidating two-year limitations period).

Factors the courts consider:

• Unequal bargaining power of the two parties
• Preclusion of a remedy under federal law
• Lack of mutuality

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