In IBEW-NECA Local 505 Health & Welfare Plan et al. v. SmithKline Beecham Corp., Eastern District of Pennsylvania Judge Anita Brody certified a class of indirect purchasers of Flonase in five states. In their suit, plaintiffs accuse GlaxoSmithKline PLC of improperly blocking rivals from bringing generic versions of the nasal spray to market by filing multiple “citizen petitions” with the FDA right before the company’s exclusive rights for Flonase were due to expire. In their class certification motion, plaintiffs sought to include consumers of Flonase throughout the U.S. However, the court held that the class could only incorporate members in the same states as the case’s named plaintiffs because although generally, named plaintiffs may represent other plaintiffs with common but not identical claims, indirect purchasers cannot attempt to expand their class to include states in which no named plaintiff has demonstrated injury.