In 2005, Congress passed the Class Action Fairness Act, a multifaceted piece of legislation that had as one its main goals to expand federal jurisdiction over class actions. The act responded, in part, to complaints regarding state courts in certain jurisdictions that had become notorious for allegedly favorable treatment of the plaintiffs’ bar and a tendency to be overly lenient in the certification of class actions. The removal of class actions from the state court in which they were filed to a federal court was made easier by removing the requirement of complete diversity of citizenship (i.e. the mandate that diversity jurisdiction would not apply if any plaintiff shared state citizenship with the defendant) and allowing individual plaintiffs’ claims to be aggregated for purposes of calculating the amount in controversy. Before CAFA, removal to federal court was permitted only if a single plaintiff existed with a claim in excess of $75,000; afterwards, a class of at least 100 members and with aggregate claims of $5,000,000 was sufficient.