The State of Washington and other state attorneys general brought antitrust actions against LCD manufacturers in state court. Defendants removed the actions to federal court under CAFA, and the district court remanded the cases to state court. On review of the remand order, the Ninth Circuit held that the actions were properly remanded. Washington v. Chimei Innolux Corp., 659 F.3d 843 (9th Cir. 2011) (No. 11- 16862). The Ninth Circuit recognized that CAFA’s removal jurisdiction is strictly construed and that parens patriae actions do not fall within CAFA’s definition of class actions. CAFA defines “class action” to include a civil action filed under Rule 23 or a similar state statute. The parens patriae actions did not qualify. While class actions are always representative actions, not every representative action is a class action. The court compared the parens patriae actions to other representative actions, such as EEOC enforcement actions. Relying on the plain language of CAFA, the court declined defendants’ effort to interpret the statute based upon comments in the legislative history.