The Class Action Fairness Act ("CAFA") lowers the bar for diversity jurisdiction for class actions and so-called "mass actions." In Mississippi ex rel. Hood v. Au Optronics Corp. (http://www.metnews.com/sos.cgi?0114//12-1036_0971), the Supreme Court clarified what constitutes a "mass action." In Au Optronics defendant argued that a case brought by the State of Mississippi seeking recovery on behalf of itself and its citizens was not a "mass action" within the meaning of CAFA and could not be removed to federal court under the more forgiving diversity jurisdiction for mass actions. Because only one plaintiff, the state, was named, the case was not in the Supreme Court's view a "mass action."