Under the American Pipe doctrine, the commencement of a class action tolls the statute of limitations for absent class members. American Pipe & Construction Co. v. Utah, 414 U.S. 538, 554 (1974). The intent of this rule is to protect the interests of class members and preserve the efficiencies of class litigation. Without tolling, absent class members would need to intervene or file individual claims to preserve their rights if the court denies class certification. See Crown, Cork & Seal Co. v. Parker, 462 U.S. 345, 350 (1983). We have discussed American Pipe tolling on the blog before ...
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