Plaintiff filed a class action claiming defendant sent thousands of junk faxes in violation of the Telephone Consumer Protection Act. The parties negotiated a settlement under which defendant consented to a substantial judgment. Plaintiff agreed not to attempt to recover the judgment from the defendant, but instead would seek recovery under defendant’s insurance policy, which defendant assigned to the class as part of the settlement. Plaintiff then filed a new state court action against the insurer, seeking a declaration that the insurer was liable for the judgment. Plaintiff sued individually and as a representative of a certified class. The insurance company defendant removed the case to federal court. Plaintiff dismissed its complaint, filed a new complaint seeking relief as an individual, and sought to remand. The district court remanded the action, and the Seventh Circuit reversed. Addison Automatics, Inc. v. Hartford Cas. Ins. Co., 731 F.3d 740 (7th Cir. 2013) (No. 13-2729). The Seventh Circuit found that the action was in substance a class action and was removable. First, plaintiff had standing to pursue relief only as a class representative. Second, plaintiff owed continuing fiduciary obligations to the class it represented. Thus, filing an amended complaint as an individual action did not change the reality that the plaintiff was pursuing claims on behalf of the class. Because the plaintiff remained the representative of a certified class, removal was proper under CAFA.