Between August 2010 and November 2011, several hundred plaintiffs filed ten lawsuits in Illinois state court against Abbott Laboratories for personal injuries caused by Depakote. In December 2011, plaintiffs moved the Supreme Court of Illinois to consolidate and transfer their cases pursuant to Illinois Supreme Court Rule 384, which provides that civil actions involving one or more common questions of fact or law may be transferred “to one judicial circuit for consolidated pretrial, trial, or post-trial proceedings.” The Court found that: “Although plaintiffs assert that the transferee court will decide how their cases proceed to trial, it does not matter whether a trial covering 100 or more plaintiffs actually ensues; the statutory question is whether one has been proposed. Section 1332(d)(11)(B)(i) does not say where a proposal for a joint trial must be made, but a reasonable conclusion is that it must be made to a court that can effect the proposed relief. Here, plaintiffs filed their motion to consolidate with the Supreme Court of Illinois, which has the power not only to consolidate plaintiffs’ cases through trial but also to decide where plaintiffs’ cases will ultimately be. As a result, plaintiffs’ motion to consolidate was sufficient to create a mass action.” In re Abbott Laboratories, Inc., 698 F.3d 568 (7th Cir. 2012).