In a recent Class Action Alert, DLA Piper reminds defendants that, as of January 2009, settlements of California class actions cannot include dismissal of the class action as part of the settlement.  (Totino, Briones & Tagvoryan, California: Defendants May No Longer Request Dismissal of Settled Class Actions (May 27, 2009) www.dlapiper.com.)  Instead, California Rule of Court 3.769 requires a trial court that approves a class action settlement to enter a judgment and prohibits the entry of an order dismissing the action with or after entry of judgment.  Speaking from personal experience, defendants are not thrilled with this new development and many practitioners are still unaware of this changed rule.