A midsized U.S. law firm (“the law firm”), represented XYZ, a popular washing machine manufacturing company, in a class action alleging that XYZ’s washing machines have an inherent design defect and that the XYZ continued to sell the machines when it knew of the defect. The original class action sought to represent purchasers who reside in one of the States, but the purchasers have amended their complaint and also seek certification for those purchasers that then also resided in other States. The lawsuit sought to certify classes of consumers that purchased those defective models of washing machines that reside in various States. The Multi District Litigation was assigned to a Federal Court. Before preferring a Motion for Class Certification, in the meantime, XYZ had pursued discovery regarding the extent to which various defective models were involved or, the extent to which XYZ’s on-going design changes fixed such defects.