d with the Second Circuit's decision in Caridad v. Metro-North Commuter Railroad, 191 F.3d 283 (2d Cir. 1999). See Brown I, 576 F.3d at 157 (citing Caridad, 191 F.3d at 293). But by the time Brown I was issued, the Second Circuit ("94] had already repudiated any part of Caridad suggesting a lesser burde

f the evidence. See In re IPO, 471 F.3d at 42 ("[O]ur conclusions necessarily preclude the use of a 'some showing' standard, and to whatever extent Caridad might have implied such a standard for a Rule 23 requirement, that implication is disavowed."). Only one circuit followed Brown l's lead and accepte

uit alone on an island. The Brown I majority suggested that its lenient view of the necessary evidence aligned with the Second Circuit's decision in Caridad v. Metro-North Commuter Railroad, 191 F.3d 283 (2d Cir. 1999). See Brown I, 576 F.3d at 157 (citing Caridad, 191 F.3d at 293). But by the time Brow

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