When a complaint only alleges the value of the class representative’s claim, a class-action defendant need not consult its business records and devise a representative valuation of class members’ claims in order to determine whether the amount in controversy exceeds the Class Action Fairness Act’s $5 million threshold for
removal. Kuxhausen v. BMW Financial Services, No. 12-57330, slip op. at *8-11 (9th Cir. Feb. 25, 2013). Nor must the defendant make a “plausible-enough guess” as to the value of the other claims. Id. While “multiplying figures clearly stated in a complaint” is clearly required of a defendant, “mak[ing] extrapolations or engag[ing] in guesswork” is not. Id. (quotations omitted). This rule ensures that the costs associated with indeterminate pleadings are borne by their authors. Id. at *10.