Does the Mazza class need to be certified for litigation purposes?

Importantly, the Mazza class was certified for litigation purposes. The prospect of having to apply the separate laws of dozens of jurisdictions presented a significant issue for trial manageability, weighing against a predominance finding.⁷ See also Zinser v. Accufix Research Inst., Inc. , 253 F.3d 1180, 119092 (9th Cir. 2001) (treating state law variations as a subspecies of trial manageability concerns). In settlement cases, such as the one at hand, the district court need not consider trial manageability issues. Amchem , 521 U.S. at 620, 117 S.Ct. 2231.