An MDL transferee presiding over Light Cigarette Litigation, Judge John A. Woodcock, Jr., issued an opinion recently denying class certification for lack of predominance, superiority and/or constitutional standing. The court analyzed the requirements of Rule 23(a), and concluded that the proposed classes met each of these requirements: numerosity, commonality, typicality and adequacy of representation. The court concluded, that the predominance requirement of Rule 23(b)(3) was not met, however, because plaintiffs could not establish causation and injury with class wide proof. Please click here to read the order.