We previously reported to you the case of Radcliffe v. Experian Information Solutions, Inc., 715 F.3d 1157 (9th Cir. 2013), in which the Ninth Circuit held that incentive awards in a settlement rendered the class representatives inadequate. The incentive awards were conditional – they would only be granted to those class representatives who supported the settlement. On remand, a group of class members moved to disqualify class counsel. They asserted there was a conflict between the named representative who sought the conditional incentive awards and the unnamed members of the class. The district court applied California law and concluded that automatic disqualification was not necessary. White v. Experian Info. Solutions, No. SACV 05-01070 (C.D. Cal. May 1, 2014). The conflict was brief, was caused by a provision in a settlement that was no longer applicable, and it arose not from the underlying interests of the plaintiffs, but rather the faulty settlement terms. Balancing the interests of parties, counsel, and the court, the court declined to disqualify counsel and refused to appoint substitute counsel for the class.