because plaintiffs “offer no basis to find that putative class members will have retained a receipt, bottle label, or any other concrete documentation of their purchases”). The Court agrees with Judge Rakoff s reasoning in Ebin. Declining to certify classes when consumers are likely to lack proof of purchase “would render class actions against producers almost impossible to bring.” Ebin v. Kangadis Food Inc., 297 F.R.D. at 567. “Yet the class action device, at its very core, is designed for cases like this where a large number of consumers have [allegedly] been defrauded but no one consumer has suffered an injury sufficiently large as to justify bringing an individual lawsuit.” Id.; see also Amchem Prods., Inc. v. Windsor, 521 U.S. 591, 617, 117 S.Ct. 2231, 138 L.Ed.2d 689 (1997) (<HOLDING>). If proof of purchase was required to satisfy
holding that if small claims court judgments do not have claim preclusive effect then small claims courts become a false forum and these policy objectives are not met recognizing that when what is small is not the aggregate but the individual claim  thats the type of case in which class action treatment is most needfulf and emphasizing that a class action has a deterrent as well as a compensatory objective holding that facilitating small claims is the policy at the very core of the class action mechanism holding that claim preclusion applies to small claims court adjudication and that judicial economy is not served by encouraging resolution of property claims in small claims court and other claims in district court holding that because no class was certified at the time the individual claims were dismissed the class action was properly dismissed