A suit alleging mass-market fraud on the part of Zions First National Bank and its subsidiaries gave the Third Circuit a chance to examine the standards for class certification.

Last year, U.S. District Judge Juan R. Sanchez of the Eastern District of Pennsylvania denied certification of the class because the plaintiffs hadn’t satisfied the commonality and predominance requirements, saying they hadn’t established classwide injury since they hadn’t given the court proof that the bank had defrauded all the class members.

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