In Neale v. Volvo Cars of North America, LLC, 794 F.3d 353 (3d Cir. 2015) (No. 14-1540), the Third Circuit held that unnamed, putative class members do not need to establish Article III standing.  Instead, the requirements of Article III are satisfied as long as the class representative has standing, either in the context of a settlement or litigation class.  The Third Circuit noted that its ruling potentially conflicted with the decisions of other circuits, but further held that requiring Article III standing of absent class members would be inconsistent with Rule 23.  The court reversed the certification of the class and remanded it to the trial court for consideration of whether plaintiff had satisfied the predominance requirements and for the district court to define the class and the claims certified.