Earlier this year, the Eighth Circuit issued a decision in the Target data breach litigation, in which it found that the district court, in approving the settlement class, had not engaged in a proper rigorous analysis.  In particular, the court failed to address whether a potential intra-class conflict existed that might render the class representatives inadequate.  On remand, plaintiffs renewed their motion for certification of the settlement class.  Addressing the intra-class conflict, plaintiffs identified class representatives able to represent class members with actual money damages and class members who might have future injury.  See In re Target Corp. Customer Data Sec. Breach Litig., MDL No. 14-2522 (D. Minn. May 17, 2017).  The district court found the class representatives were adequate and certified the class.  The court held that there was no conflict of interest because the class was structured to remedy present and future injuries, and there were class representatives in each group.