placed charges on purchasers' credit cards for "memberships.” The complaint in Ritt includes language and allegations specific to the Tae-Bo product. It sought certification of a nationwide class of those individuals "who were charged unauthorized fees (or similar unauthorized charges) on their credit card or debit ca . Co., 492 F.3d 986, 997 (8th Cir.2007) (assuming without deciding that American Pipe analysis applies in cases where one putative class action suit was dismissed without prejudice and one was voluntarily dismissed). Even those circuits that apply a categorical ban against tolling for the benefit of subsequent class actions have addressed situations in which class certification has been affirmatively denied. See Griffin v. Singletary, 17 F.3d 356, 359 (11th Cir.1994) (<HOLDING>); Salazar-Calderon v. Presidio Valley Farmers
holding that tolling applies to a subsequent class action when class certification was granted in a prior case holding that tolling applies to a subsequent class action when the prior denial of class certification was based solely on rule 23 deficiencies of the putative representative holding that putative class members are not parties to an action prior to class certification holding that a class action tolls the statute of limitations only for subsequent individual actions not for subsequent class actions holding that no subsequent class actions may benefit from tolling when class certification has been denied