Washington International Law Journal


In September 1994, the United States District Court for the Northern District of Alabama approved a multi-billion dollar settlement in a global class action for breast implant recipients. The court concluded its opinion by excluding women from Australia, Ontario and Quebec from the settlement. After examining U.S. class action procedural requirements and analyzing the District Court's opinion, this Comment argues that the court improperly applied the procedural requirements for a class action to the detriment of the potentially injured women from Australia, Ontario and Quebec.

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