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(For example, in a toxic-tort case, perhaps the class members' exposure varies by time or location.) Defendants facing a motion to certify an issue class also should emphasize the plaintiff's burden to articulate (i) the certifiable issues clearly, and (ii) how an issue class satisfies Rule 23(b)(3)'s superiority requirement, given the individualized issues that would remain.

Maternal cigarette smoking before or during pregnancy increases the risk of birth congenital anomalies: a population-based retrospective cohort study of 12 million mother-infant pairs

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New Engl J Med 370:6068 Krishna A, Ahluwalia R (2008) Language choice in advertising to bilinguals: asymmetric effects for multi- nationals versus local firms