In In re Kosmos Energy Ltd. Securities Litigation, No. 12-CV-373 (N.D. Tex. Mar. 19, 2014), plaintiffs sought certification of a class to pursue claims under the Securities Act of 1933.  The district court denied certification, finding the plaintiff was not an adequate class representative because he had only rudimentary knowledge of the case.  Indeed, when deposed, the named plaintiff was unable to provide specifics of the claim.  The court found adequacy of representation, which is an element of due process in a class action, to be absent.  Following WalMartand Comcast, the court applied a rigorous analysis to adequacy of representation, which the plaintiff failed to meet.  The court also found plaintiff had failed to provide sufficient evidence showing predominance.