Richards v. Direct Energy Servs., LLC, 2015 U.S. Dist. LEXIS 157071 (D. Conn. Nov. 20, 2015):
1 The Court notes that there appears to be a Circuit split between the Seventh and Second Circuit on the issue of whether class certification should be decided before standing. See 6803 Boulevard East, LLC v. DIRECTV, LLC, 17 F. Supp. 3d 427, 431-32 (D.N.J. 2014) (describing the different approaches taken by the Second and Seventh Circuits).
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