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The U.S. Supreme Court’s decision in Wal-Mart Stores, Inc. v. Dukes, 131 S. Ct. 2541 (2011) has impacted millions of employees in their pursuit of class action claims against their employers. The Dukes decision articulated the standard for establishing the commonality necessary to secure class certification in a manner that has been seen to raise the bar to class certification under Federal Rule of Civil Procedure 23.

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