basis, a parens patriae lawsuit is brought by a public entity in its sovereign or quasi-sovereign interest and represented by salaried states’ attorneys. With respect to the prerequisites, Plaintiff contends that this type of suit is fundamentally different than a class action: the latter requires numerosity, typicality, and commonality, whereas the former imposes no such constraints. Finally, Plaintiff argues that class actions impose rigorous procedural safeguards to protect absent class members; by contrast, in parens patriae suits, the safeguards are limited to due process and the democratic process. Plaintiff thus concludes that this action is a “separate and distinct procedural vehicle from a class action.” Breakman v. AOL LLC, 545 F.Supp.2d 96, 101, 102 (D.D.C.2008) (<HOLDING>); see also Harvey v. Blockbuster, Inc., 384
holding that a district of columbia consumer protection statute that authorized representative actions and did not reference class action requirements or mandate class certification was a separate and distinct procedural vehicle from a class action and thus did not constitute a class action under cafa holding that no subsequent class actions may benefit from tolling when class certification has been denied holding that putative class members are not parties to an action prior to class certification holding that where named plaintiff was employee of class counsel district court did not abuse its discretion by denying class certification holding that tolling applies to a subsequent class action when class certification was granted in a prior case