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First was the suggestion of Harry Kalven, Jr. And iPhone Cases Maurice Rosenfield in 1941 that class action litigation by individual shareholders on behalf of all shareholders of a company could effectively supplement direct government regulation of securities markets and other similar markets.[2]:232 The second development was the rise of the civil rights movement, environmentalism and consumerism.[2]:240 244 The groups behind these movements, as well as many others in the 1960s, 1970s and 1980s, all turned to class actions as a means for achieving their goals. For example, a 1978 environmental law treatise reprinted the entire text of Rule 23 and mentioned "class actions" 14 times in its index.[2]:244 245Businesses targeted by class actions for inflicting massive aggregate harm have sought ways to avoid class actions altogether.

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