FAA section 1 (9 USC 1) exempts contracts of employment of seamen, railroad employees and other workers in interstate or foreign commerce from the FAA’s other provisions.  This decision holds that the exemption’s focus is on the work performed by the employee, not the industry in which the employer is engaged.  Even if the employer is not in any transportation industry, section 1 still exempts any of its employees who are actively engaged in transportation of goods across borders via the channels of foreign or interstate commerce.  Any exempt worker must at least play a direct and ‘necessary role in the free flow of goods’ across borders.