On October 6, Jennifer Mesko co-presented a Strafford live webinar, “Rule 23(c)(4) Issue Certification: Reconciling the Conflict With Rule 23(b)(3)’s Predominance Requirement.” Jenn and her co-panelists examined limited issue certification under Rule 23(c)(4) and the three-way split that has developed among the circuits regarding how narrowly or broadly to interpret that rule. The panel provided instruction on considerations and strategies for litigating certification under Rule 23(c)(4) based on recent case law and their own practical experiences.