that the named plaintiffs are not “typical” of the majority of potash purchasers in the putative class. Although the Plaintiffs admittedly purchased potash in smaller quantities and were not privy to special high-volume benefits available to their larger counterparts, Rule 23(a)(3) does not require that all members of a proposed class pay the same amount or use similar purchase methods in order to pursue an antitrust price-fixing claim. Similarly, Rule 23(a)(3) does not require the representative plaintiffs to have the same claim size or financial interest as the class they seek to represent. Courts routinely have held that “small” claim size will not prohibit class certification. See Herbert B. Newberg & Alba Conte, Newberg on Class Actions § 3.27 at 3-146-47 & n. 388 (3d ed. 1992) (<HOLDING>) (citing cases). Thus the focus of Rule
holding that choiceoflaw issues prevented a manageable class under rule 23a holding that rule 23a requirements must be satisfied as if class were to litigate its claims 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 recognizing that the number of class representatives is not significant under rule 23a holding that a proposed class of 40 was a sufficiently large group to satisfy rule 23a