On January 18th, the U.S. District Court for the Southern District of New York denied class certification in a mortgage-backed securities offering fraud case. Plaintiffs in the action allege that offering documents for interests in pools of securitized home mortgages misrepresented the underlying mortgages' compliance with underwriting standards. Because unique defenses stemming from varying levels of investor sophistication predominate, the Court denied class certification. New Jersey Carpenters Health Fund v. Residential Capital LLC.