Many had tried, but all failed to address, organize, or settle the sprawling number of cases contained within asbestos multidistrict litigation MDL-875 since its inception in 1991.

Neither legislation nor class action designation had put a dent into the massive volume of cases within the MDL, referred to by some as a black hole; by the time U.S. District Judge Eduardo Robreno was assigned to the matter in 2008, he was facing the challenge of managing more than 180,000 individual cases representing millions of claims.