In Vassalle v. Midland Funding LLC, 708 F.3d 747 (6th Cir. 2013), plaintiffs had complained that defendants used robo-signed affidavits in collecting consumer debt. The parties reached a proposed settlement, under which defendant: agreed to pay $5.2 million to a common fund, $1.5 million to class counsel, and $8000 in total to the four class representatives and release their respective debts to defendant; agreed to pay an amount which would be distributed to the class members, resulting in payments to each member of approximately $17; and agreed to implement procedures so it would not submit robo-signed affidavits. In exchange, the class would release all claims against defendant, including claims relating to robo-signing. The court found the settlement was unfair because it gave preferential treatment to the representative plaintiffs, while only providing perfunctory relief to the class. Unlike the named plaintiffs, the class members did not receive the exoneration of their debts even though the settlement eliminated the class members’ key defense to debt collection. The court found the representatives had no interest in prosecuting the unnamed class members’ ability to challenge the false affidavits in their debt collection proceedings because the class representatives obtained a release of their debts in exchange for approving a settlement that would prevent class members from challenging their debts. The court also found class notice to be insufficient because it did not explain the nature of the claims being released.