"Many courts do not now require that a class definition exclude the possibility that a class member suffers no injury.... A Tyson win therefore could mean that a putative ERISA class challenging a defective Summary Plan Description that applied to a class of plan participants will not be certified unless class counsel can trace the defect, in roadmap fashion, to a common injury for each class member. It could mean that a putative ERISA class challenging allegedly excessive fees for a plan investment in a defined contribution plan will not be certified unless class counsel can show how each class member will receive a common increase in benefits should the claim succeed." [Tyson Foods v. Bouaphakeo, No. 14-1146 (8th Cir. Aug. 25, 2014; cert. pet. granted June 8, 2015)]