In what turned out to be a preview of the U.S. Supreme Court’s Wal-Mart v. Dukes decision, the Seventh Circuit Court of Appeal, in Randall v. Rolls-Royce Corp., affirmed the denial of certification of a class of more than 500 female employees of Rolls-Royce who alleged they were underpaid and under-promoted on the basis of gender. Despite seeking primarily monetary relief, which is characteristic of 23(b)(3) classes, plaintiffs presented their requested relief as an injunction under Rule 23(b)(2), which governs a class in which “final injunctive relief or corresponding declaratory relief is appropriate respecting the class as a whole.” In its March 30, 2011 decision, the Seventh Circuit explained that it may be “easier” to establish the requisite adequacy of the class representatives in a (b)(2) class because “usually there is less variance in injunctive relief” than in a (b)(3) class seeking damages. But the court rejected the claim that a (b)(2) class could be maintained in this case, where “the equitable relief is mainly monetary.” Rule 23(b)(2), the court stressed, envisions a class remedy of “final” injunctive relief, which would not apply here, where “calculating the amount of back pay to which the members of the class would be entitled if the plaintiffs prevailed would require 500 separate hearings.” The court further explained that it “is only when the primary relief sought is injunctive,” and where monetary relief (if sought) is “mechanically computable,” that (b)(2) is applicable.