In recent years, federal appellate courts have emphasized the need for class members to be readily ascertainable. In EQT Production Co. v. Adair, Nos. 13-414, et al. (4th Cir. Aug. 19, 2014), the Fourth Circuit added its voice to the chorus of courts emphasizing the need that a class be ascertainable. Relying on its prior law that members of a proposed class must be “readily identifiable,” the court stated that class cannot be certified unless the court can readily identify the class members in reference to objective criteria. At class certification, plaintiffs need not be able to identify every class member. But, if class members cannot be identified without individualized fact-finding or mini-trials, a class is inappropriate. In EQT, the court faced claims arising out of mineral royalty escrow disputes. On appeal, the Fourth Circuit concluded that because the ownership of a mineral estate frequently changes, and the records reflecting those changes are not easily identifiable, the case presented issues concerning verifying ownership of those class members to receive royalties. The district court had failed to address this issue, and the Fourth Circuit remanded the case for further consideration of whether the class could be identified. The court also remanded for further consideration of commonality.