"As recent decisions from federal courts in New Jersey and California illustrate, where plaintiff classes seek to challenge decisions by ERISA healthcare plan administrators, commonality is best achieved when the same benefit plan provision is at issue, as well as the same reason for denial of claims. Each of the cases discussed below involved a putative class pursuing claims against health plans based on denials and alleged underpayments for out-of-network services, and the classes in both cases failed to achieve certification."

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