On the recommendation of a United States Magistrate Judge for the Pittsburgh Division, the U.S. District Court for the Western District of Pennsylvania has granted class certification in a dispute between lessors and a lessee over royalty payments made under oil and gas leases. In Pollock v. Energy Corp. of Am., No. 10-1553, 2013 U.S. Dist. LEXIS 141139 (W.D. Pa. Sept. 16, 2013), the putative class representatives, all of whom had entered into oil and gas leases with the lessee defendant, essentially raised three allegations against the lessee defendant that were used to certify subclasses under Rule 23(c)(4).