1. Whether there is an implied "administrative fea-
sibility" prerequisite for class certification, as held by
the First, Third, and Fourth Circuits, or whether ad-
ministrative feasibility is merely a factor to be
weighed in determining whether class certification is
"superior" to the alternatives under Rule 23(b)(3), as
held by the Second, Sixth, Seventh, Eighth, Ninth, and
Eleventh Circuits. See Cherry , 986 F.3d at 1302;
Briseno v. ConAgra Foods, Inc., 844 F.3d 1121, 1133
(9th Cir. 2017); In re Petrobras Sec., 862 F.3d 250, 267
(2d Cir. 2017); Sandusky Wellness Ctr., LLC v.
Medtox Sci., Inc., 821 F.3d 992, 996 (8th Cir. 2016);
Rikos v. Procter & Gamble Co., 799 F.3d 497, 525
(6th Cir. 2015); Mullins v. Direct Digital, LLC , 795
F.3d 654, 662 (7th Cir. 2015).

2. Whether the TCPA's definintion of "telephone
facsimile machine" is limited to traditional "stand-
alone" fax machines, as the Fourth Circuit held in this
case, or whether the "plain language" of the definition
"encompasses more than traditional fax machines that
automatically print a fax received over a telephone
line," as the Sixth Circuit held in Lyngaas , 992 F.3d at
426.

Whether there is an implied 'administrative feasibility' prerequisite for class certification