In Luther v. Convergent Outsourcing, Inc., 2016 WL 1698396, at *6 (E.D.Mich., 2016), Judge Cohn certified an FDCPA class action, finding that the small class recovery was no impediment to class certification.
A class action is superior “[w]here it is not economically feasible to obtain relief within the traditional framework of a multiplicity of small individual suits for damages, aggrieved persons may be without any effective redress unless they may employ the class-action device.” Young v. Nationwide Mut. Ins. Co., 693 F.3d 532, 545 (6th Cir. 2012)(quoting Deposit Guar. Nat’l Bank v. Roper, 445 U.S. 326, 339 (1980)). On a similar note, “[a] class action is superior where potential damages may be too insignificant to provide class members with incentive to pursue a claim individually.” Randolph v. Crown Asset Mgmt., LLC., 254 F.R.D. 513, 520 (N.D. Ill. 2008)(quoting Jackson v. Nat’l Action Fin. Servs., Inc., 227 F.R.D. 284, 290 (N.D. Ill. 2005). Here, where each individual class member’s recovery would be small and the class size is large, combining identical claims into a single action is the superior and most efficient way to resolve the claims.