Under American Pipe & Constr. Co. v. Utah (1974) 414 U.S. 538, 552-53, and Crown, Cork & Seal Co. v. Parker (1983) 462 U.S. 345, 350, 354, it is well-settled that the filing of a class action tolls the statute of limitations period for all putative class members until class certification is denied, at which point individual class members may decide whether to file their own lawsuits or move to intervene in the pending action.[i] The issue in this case was whether the tolling period could be applied where a class action did not end with denial of class certification.