in controversy requirement to establish diversity jurisdiction. Zahn v. International Paper Co., 414 U.S. 291, 301, 94 S.Ct. 505, 512, 38 L.Ed.2d 511 (1973); Snyder v. Harris, 394 U.S. 332, 338, 89 S.Ct. 1053, 1057-58, 22 L.Ed.2d 319 (1969). But, plaintiffs no longer have to comply with the Zahn rule because Zahn was effectively overruled by 28 U.S.C. § 1367. Only the named plaintiff must satisfy the jurisdictional amount in controversy requirement. Although the Third Circuit has not yet addressed the issue, see, e.g., Packard, 994 F.2d at 1045-46 n. 9, a plain reading of section 1367(a) clearly permits the exercise of supplemental jurisdiction over class plaintiffs’ claims that do not meet the amount in controversy requirement. See In re Abbott Labs., 51 F.3d 524, 529 (5th Cir.1995) (<HOLDING>); Deep v. Manufacturers Life Ins. Co., 944
holding that omission was not plain error holding that by its plain meaning section 1367 overrules clark v paul gray inc 306 us 583 59 sct 744 83 led 1001 1939 in which the supreme court held in a nonclass action case that each plaintiffs claim must satisfy the amount in controversy requirement recognizing plain or fundamental error holding that a plain reading of section 1367 overrules zahn holding plain language compelled that reading