Before 1966, Rule 23 was silent on how to determine which class members would be bound by a judgment before it was entered. American Pipe & Construction v. Utah, 414 U.S. 538, 545–46 (1974). Instead, some took Rule 23 as an open invitation for potential class members to join the lawsuit without any commitments, allowing them to sit and wait until a trial was over to determine whether to definitively accept the invitation to join. If the class claims were  successful, class members could intervene and reap the benefits; if the class claims failed, class members could stay on the sideline and avoid having their claims precluded. Thus, one way intervention was equivalent to "a free-agent baseball player … [sitting] on the sidelines during the middle of the playoffs while watching the Astros and the Rangers play a game, then decid[ing] which team to sign onto only after that team has won." In re Parish, 81 F.4th 403, 413 (5th Cir. 2023) (emphasis in original). This potential right of "one-way intervention" prompted the Advisory Committee to close this perceived loophole when it significantly revised Rule 23 in 1966. American Pipe, 414 U.S. at 547.