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Lord Aga · 03-19-2008, 03:07 PM

15. Pursuant to Federal Rules of Civil Procedure 23 (a) and 23(b)(2) and/or (3),
NRM brings this action and seeks certification on behalf of a class (the “Class”), consisting
of:
All persons and entities who operate Affiliate Programs and who
purchased information processing services for such purpose from
TMM based on NATS, a software program owned, designed and sold
by TMM and/or Albright and/or Berrebbi in interstate commerce from
2004 to date. Excluded from this Class are the TMM Defendants,

TMM’s officers, directors, and employees, Doe Defendants 1 through
30, and any judicial official to whom this matter is assigned.
16. The Class is so numerous that joinder of all members is impracticable. While
the exact number of Class members is unknown to NRM at this time and may only be
ascertained through discovery, NRM believes there are several hundreds of members in the
proposed class.
17. The claims of NRM are typical of the claims of the members of the Class,
because NRM and all Class members sustained damages out of defendants’ wrongful
conduct complained of herein.
18. NRM will fairly and adequately protect the interests of the Class. NRM has
no interests antagonistic to those of the Class, and has retained counsel and consultants
experienced in consumer class action litigation and who are further familiar with the
technical aspects of the Affiliate Program business model.
19. A class action is superior to other available methods for the fair and efficient
adjudication of the claims asserted herein, because the expense and burden of litigation, and
the power to deny members of the Class vital information-processing services that would
lead to the collapse of their business, make it virtually impossible for the Class members to
pursue individual redress for the wrongs they have suffered and continue to suffer. The
likelihood of individual members of the Class prosecuting individual, separate claims is
remote.
20. In addition, members of the Class reside in many states throughout the United
States and in foreign countries and are so numerous that it will be impracticable to join them
each individually. However, it will be highly practicable to ascertain their identities and to
communicate with them because TMM has a list of all members of the Class.

03-19-2008, 03:07 PM	#3 (permalink)
Lord Aga Next one to change this gets broken legs!! Join Date: Sep 2002 Posts: 1,714 Points: 60,200	15. Pursuant to Federal Rules of Civil Procedure 23 (a) and 23(b)(2) and/or (3), NRM brings this action and seeks certification on behalf of a class (the “Class”), consisting of: All persons and entities who operate Affiliate Programs and who purchased information processing services for such purpose from TMM based on NATS, a software program owned, designed and sold by TMM and/or Albright and/or Berrebbi in interstate commerce from 2004 to date. Excluded from this Class are the TMM Defendants, TMM’s officers, directors, and employees, Doe Defendants 1 through 30, and any judicial official to whom this matter is assigned. 16. The Class is so numerous that joinder of all members is impracticable. While the exact number of Class members is unknown to NRM at this time and may only be ascertained through discovery, NRM believes there are several hundreds of members in the proposed class. 17. The claims of NRM are typical of the claims of the members of the Class, because NRM and all Class members sustained damages out of defendants’ wrongful conduct complained of herein. 18. NRM will fairly and adequately protect the interests of the Class. NRM has no interests antagonistic to those of the Class, and has retained counsel and consultants experienced in consumer class action litigation and who are further familiar with the technical aspects of the Affiliate Program business model. 19. A class action is superior to other available methods for the fair and efficient adjudication of the claims asserted herein, because the expense and burden of litigation, and the power to deny members of the Class vital information-processing services that would lead to the collapse of their business, make it virtually impossible for the Class members to pursue individual redress for the wrongs they have suffered and continue to suffer. The likelihood of individual members of the Class prosecuting individual, separate claims is remote. 20. In addition, members of the Class reside in many states throughout the United States and in foreign countries and are so numerous that it will be impracticable to join them each individually. However, it will be highly practicable to ascertain their identities and to communicate with them because TMM has a list of all members of the Class.