We previously reported to you concerning whether a state attorney general could invoke CAFA jurisdiction for parens patriae actions.  In Mississippi ex rel. Hood v. AU Optronics Corp., 134 S. Ct. 736 (2014) (No. 12-1036), the U.S. Supreme Court reversed the decision on which we previously reported and held that when a State is the only named plaintiff, the suit does not constitute a mass action under CAFA.  The Court held the term “plaintiff” does not include both named and unnamed plaintiffs.  Based on the statute’s text and context, CAFA’s “100 or more persons” standard does not include unnamed persons who are real parties in interest to claims brought by the named plaintiff.