In Ronat v. Martha Stewart Living Omnimedia, the plaintiffs alleged that certain Martha Stewart brand patio tables sold at K-Mart had defective glass tops that tended to shatter spontaneously. The plaintiffs sought to certify a multi-state class for breach of implied warranty and unjust enrichment under the laws of several states. The district court denied class certification, noting the Seventh Circuit’s recent decision in Thorogood v. Sears, Roebuck & Co., which explained that federal court class treatment of “half a million claims wrested from the control of the courts of 29 jurisdictions in which those claims arose and the laws of which govern the claimants’ entitlement to and scope of relief” would be inappropriate on Rule 23 superiority and manageability grounds, and would undermine federalism. Following Thorogood, the district court denied certification, stating: “[T]his Court can’t grasp why a district court in Illinois should try implied warranty and unjust enrichment claims arising under the laws of [five states].” The Ronat court found that the plaintiffs failed to establish Rule 23 manageability or superiority, and that the proposed class and subclass definitions were “even more unmanageable because of differences in the statutes of limitations that apply under the different states’ laws.” The court also found that predominance was lacking because individualized proof of spontaneous shattering would be required by the class definition, and that inherent difficulties existed in identifying class members whose table tops had spontaneously shattered versus those whose tops either had not broken at all or had shattered due to some other cause.