In Barber v. American Airlines, 241 Ill. 2d 450 (Ill. 2011), the Illinois Supreme Court held that a class action may be dismissed as moot when the defendant tenders full relief to the named plaintiff prior to the filing of a motion for class certification. Following Barber, plaintiffs typically have filed a motion for class certification with their complaints. The filing of a motion, prior to any tender of relief, was thought to prevent defendants from being able to “pick off” class representatives by tendering full relief. In Ballard RN Center, Inc. v. Kohll’s Pharmacy and Homecare, Inc., 2015 IL 118644 (Ill. 2015), the defendant pursued the pick off strategy on one count, notwithstanding the plaintiffs’ filing of a motion for class certification. The trial court rejected the effort, but the appellate court reversed, finding that the motion for class certification was a “shell” motion, insufficient to defeat mootness. The Illinois Supreme Court reversed. The court explained that Barber contained no requirements for the class certification motion other than it be filed prior to the offer of relief. While the court agreed in principle that a “contentless ‘shell’ motion” would be sufficient to defeat mootness, it disagreed with the appellate court that the motion was a contentless shell. The motion identified the defendant, the applicable class period, the outline of the class allegations, class representatives, and referenced the class descriptions found in the complaints. To defeat mootness, the class motion need not be meritorious – it need only be filed prior to an offer of settlement such that it brings the interests of the class members before the court.