Highlights from this issue include:

• Southern District of New York denies class certification, finding significant credibility issues make proposed class representatives inadequate.
   
• Fourth Circuit reverses denial of motion to dismiss interconnected to class certification on interlocutory appeal under Rule 23(f).
   
• Fourth Circuit reaffirms ascertainability requirement based on prior panel rulings.
   
• Seventh Circuit affirms sanctions against defendants for interfering with the class notice process by communicating directly with class members and urging them to opt out.
   
• Ninth Circuit issues two opinions addressing “express aiming” of interactive websites for purposes of personal jurisdiction.
   
• Eleventh Circuit reverses denial of class certification, finding predominance requirement could be met because Fair Credit Reporting Act does not require plaintiffs to show actual damages.