Consumers brought class action against Pella for defective windows. The district court certified a (b)(2) class of owners whose windows had not yet manifested a defect in order to declare the right of replacement under the warranty. The district court also certified six state sub-classes under (b)(3) for consumers who had already suffered damage from the defect. In a Per Curiam, the Seventh Circuit affirmed. “Pella relies on various decisions from this circuit reversing the grant of class certification in consumer fraud actions to draw the broad conclusion that consumer fraud cases are inappropriate for class treatment as a general matter. But those cases did not opine that class certification was never appropriate in consumer fraud cases, only that it was inappropriate in the circumstances before it.” As to proximate causation, the Court explained that: “Under the district court’s plan, class members still must prove individual issues of causation and damages. While it is almost inevitable that a class will include some people who have not been injured by the defendant’s conduct because at the outset of the case many members may be unknown, or the facts bearing on their claims may be unknown, this possibility does not preclude class certification.” Finally, the Court rejected challenges on Seventh Amendment grounds and with respect to manageability. Pella Corp v. Saltzman, 606 F.3d 391 (7thCir. 2010).