Class Action Certification Following the Amgen and Comcast Decisions

Navigating the Issues of Predominance and the Role of the Merits Inquiry at Certification

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, April 24, 2013

Recorded event now available

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Program Materials

This CLE webinar will provide class counsel with an in-depth review and analysis of the Supreme Court's new Amgen and Comcast decisions and their impact on class certification.


On Feb. 27, 2013, the Supreme Court addressed a longstanding circuit split on the issue of the degree of proof needed at the class certification stage of certain securities cases. The Court affirmed class certification in Amgen Inc. v. Connecticut Retirement.

In contrast to statutes and recent decisions that have made it harder for securities class actions to proceed, the Court decided that proof of materiality is not required to certify a class under FRCP 23 for a fraud-on-the-market case.

On Mar. 27, 2013, the Supreme Court issued another important decision on class certification, Comcast Corporation v. Behrend. The Court reaffirmed that district courts must perform a rigorous analysis of whether a putative class satisfies the predominance criterion under FRCP 23.

Listen as our panel of experienced class action litigators analyzes the Amgen and Comcast decisions and discusses the impact of the decisions for practioners at the class certification stage.



  1. Amgen Inc. v. Connecticut Retirement
    1. Background of case
    2. Court's decision
  2. Comcast Corporation v. Benrend
    1. Background of case
    2. Court's decision
  3. Impact of the decisions
    1. Predominance in perspective
    2. Role of merits inquiry


The panel will review these and other key questions:

  • What was the Court's decision and rationale in the Amgen case?
  • What was the Court's decision and rationale in the Comcast case?
  • How can the opinions be leveraged by class action practitioners at the class certification stage?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Deborah H. Renner
Deborah H. Renner

Baker & Hostetler

Ms. Renner's practice focuses on complex commercial litigation, including the defense of consumer fraud and...  |  Read More

Andrew J. Trask
Andrew J. Trask

McGuire Woods

Mr. Trask has defended more than 100 class actions, involving all stages of the litigation process. While his work has...  |  Read More

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