Reversing a district court holding that the statute of limitations was not tolled as to individual actions filed by putative classmembers prior to a ruling on class certification, the U.S. Second Circuit Court of Appeals reasoned that “the theoretical basis on which American Pipe rests is the notion that class members are treated as parties to the class action ‘until and unless they received notice thereof and chose not to continue.’ Because members of the asserted class are treated for limitations purposes as having instituted their own actions, at least so long as they continue to be members of the class, the limitations period does not run against them during that time. Once they cease to be members of the class – for instance, when they opt out or when the certification decision excludes them – the limitation period begins to run again on their claims.”See In re: Worldcom Securities Litigation, No. 05-6979, 2007 WL 2127874 (2d Cir. July 26, 2007).