of the state action is sought. First, federal courts handling in personam cases have generally limited their decisions to enjoin state court proceedings to MDLs or complex national class actions. “Under an appropriate set of facts, a federal court entertaining complex litigation, especially when it involves a substantial class of persons from multiple states, or represents a consolidation of cases from multiple districts, may appropriately enjoin state court proceedings in order to protect its jurisdiction.” Diet Drugs I, 282 F.3d at 235. In fact, several courts have declined to enjoin state court proceedings specifically because the federal action did not involve an MDL or a certified class action. See Negrete v. Allianz Life Ins. Co. of N. Am., 523 F.3d 1091, 1103 (9th Cir.2008) (<HOLDING>); Gooch, 589 F.3d at 330-31 (declining to
holding that there was no record of a hearing about settlement objections holding that because the alleged settlement was never approved by the court under rule 9019 the settlement agreement was unenforceable holding that the commissions approval of a nonunanimous settlement agreement did not violate intervenors due process rights because the record shows that the appellant presented arguments in opposition to the settlement during the agenda conference in which the appellant was allowed thirty minutes to present its views in opposition to the settlement agreement holding a settlement privilege exists as to thirdparty discovery of settlement negotiations holding that an injunction was inappropriate because this was not an mdl case discovery was not complete no class settlement was imminent in fact as far as the record shows no serious settlement progress had been made