United States District Court Judge Susan Illston (Northern District of California) certified a class action alleging violation of Labor Code §§ 203, 226 and 2699. Lemus v. H&R Block Enterprises, LLC (N.D. Cal. December 7, 2010). It appears from the decision that the case was trimmed down from a broader set of claims; a Fourth Amended Complaint was filed by stipulation of the parties after the motion for certification was filed. The Court's fairly simple discussion suggests that the Court viewed these statutory violations as well-suited to class treatment. It is interesting to see that, thus far, most plaintiffs are apparently avoiding the uncertainty of pursuing a representative action under PAGA by simply certifying that claim along with other claims.