Inc. v. EEOC, 446 U.S. 318, 331, 100 S.Ct. 1698, 1707, 64 L.Ed.2d 319 (1980) (noting that “the adequate-representation requirement is typically construed to foreclose the class action where there is a conflict of interest between the named plaintiff and the members of the putative class”); Prado-Steiman ex rel. Prado v. Bush, 221 F.3d 1266, 1279 (11th Cir.2000) (noting that the “incentives” of the class representative must “align with those of absent class members so as to assure that the absentees’ interests will be fairly represented”) (internal quotations omitted). The Fifth Circuit has noted “the well-established rule that' the party seeking certification bears the burden of establishing all elements of rule 23(a).” Berger v. Compaq Computer Corp., 257 F.3d 475, 481 (5th Cir.2001) (<HOLDING>). The court further stated that “[ajdequacy is
holding that it is error to certify class when named class representatives are not members of the class they purport to represent recognizing a narrow class of cases in which the termination of the class representatives claim for relief does not moot the claims of the class members holding that awards of 2500 to majority of representatives and 5000 to deposed representatives were inappropriate where representatives had borne little risk by participating in litigation and provided services that could have been provided by any other class member holding that district court erred by shifting burden to defendants to show that class representatives were inadequate holding that class representatives cannot appear pro se