In Mississippi ex rel. Hood v. AU Optronics Corp., 701 F.3d 796 (5th Cir. 2012) (No. 12-60704), the Fifth Circuit found that a parens patriae action brought by the Mississippi Attorney General was a “mass action,” which could be removed to federal court. Under CAFA, mass actions are statutorily defined as cases seeking relief on behalf of 100 or more persons that are proposed to be tried jointly. The Fifth Circuit concluded that the Mississippi action was brought on behalf of Mississippi consumers, and therefore sought recovery on behalf of more than 100 persons. This issue has divided the federal courts, as other courts have reached the opposite result. On May 28, 2013, the United States Supreme Court granted the State of Mississippi’s petition to review the Fifth Circuit’s decision in AU Optronics. 81 U.S.L.W. 3494 (U.S. 2013) (No. 12-1036).