A class action was filed against Security Union Title Insurance Company alleging a systematic and illegal overcharge in premiums for title insurance policies in residential refinancing transactions. The trial court found that common issues did not predominate, as it would have to be determined on a case-by-case basis that plaintiff or his or her agent provided a copy of the plaintiff’s prior policy, (as ostensibly required under the Security policy). The court of appeal reversed, concluding that the trial court had prematurely attempted to address the substantive merits of defendant’s claims. Pointing to the certification of similar claims in New York, the court found that “the collective issues of Security Union’s practice involving the distribution of their mandated discounted refinance rates predominate over any transaction-by-transaction differences of individual consumers.” See Dubin v. Security Union Title Ins. Co., 2005 Ohio 3482 (Ohio App. July 7, 2005).