Even when a case is consolidated into a multidistrict litigation ("MDL") pursuant to 28 U.S.C. § 1407, the right to appeal accrues when an order disposing of all of the claims in that case is made, not when the remainder of the MDL proceedings later terminate. Gelboim v. Bank of America Corp., No. 13-1174 (U.S. Sup. Ct. Jan. 21, 2015). Reversing the Second Circuit Court of Appeals, the U.S. Supreme Court explained that "[c]ases consolidated for MDL pretrial proceedings ordinarily retain their separate identities, so an order disposing of one of the discrete cases in its entirety [qualifies] under [28 U.S.C.] § 1291 as an appealable final decision." At the same time, if the order disposing of an entire case addresses additional cases where other issues remain, those latter cases do not become immediately appealable. To allow a simultaneous appeal of the affected issues in those cases, a court would need to authorize an interlocutory appeal pursuant to Federal Rule of Civil Procedure 54(b).