The following excerpt is from In re Novatel Wireless Sec. Litig., Civil No.08cv1689 AJB (RBB) (S.D. Cal. 2014):
Given the "minimal" showing necessary, Movant has satisfied this final factor. See United States v. Stringfellow, 783 F.2d 821, 827 (9th Cir. 1986) (holding the burden of making the inadequacy of representation showing is minimal) overruled on other grounds by Stringfellow v. Concerned Neighbors in Action, 480 U.S. 370. Here, Plaintiffs' interest lies in ensuring its class members are compensated and individual Defen-
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