The course of the present inquiry begins with a consideration of the current obstacles confronting a diversity (b) (3) class action and proceeds toward an analysis of such considerations and the re- sulting ramifications, Special emphasis is placed on the policy aspects of the aggregation doctrine, the jurisdictional amount statute (28 U.S.C. § 1332), and the modern class action device, with specific reference to the problematic condition of the current judicial system.'
Case Comment, Zahn v. International Paper Co. - The Aggregation Principle and Its Effect on Jurisdiction in Rule 23 (b)(3) Class Actions, 22 Clev. St. L. Rev. 204 (1973)