Read the following excerpt from a US court opinion:
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that any of the shareholders participated in any fraudulent or unlawful activity. As a mere passive recipient of the ShowBiz stock, a defendant here has only a small number of possible individual defenses, such as the claim that he only acted as a conduit for the actual recipients of the stock, or that he had a smaller number of shares than alleged. In such circumstances, a court’s conclusions regarding the primary legal and factual issues in the first case would not only form the basis for the application of stare decisis in subsequent eases; they would almost inevitably prove dispositive in those cases. See Lynch Corp. v. MII Liquidating Co., 82 F.R.D. 478, 483 (D.S.D.1979) (certifying defendant class of shareholders under (b)(1)(B)); Guy v. Abdulla, 57 F.R.D. 14, 18 (N.D.Ohio 1972) . Also significant is the fact that, were the
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What is the most suitable continuation to the opinion? Your options are:
A. holding that b1b certification of a defendant class is appropriate for the purpose of deciding common issues in a bankruptcy trustees action to recover voidable preferences and fraudulent conveyances
B. holding that tolling applies to a subsequent class action when class certification was granted in a prior case
C. holding that a district of columbia consumer protection statute that authorized representative actions and did not reference class action requirements or mandate class certification was a separate and distinct procedural vehicle from a class action and thus did not constitute a class action under cafa
D. holding that individualized factual determinations precluded finding that common issues predominate reversing the class certification order
E. holding that putative class members are not parties to an action prior to class certification
Reply with [A, B, C, D, E] only.