(5 U.S.C. § 706(2)(A))   44.  Named plaintiff HFTX brings this action on behalf of itself and all other similarly  situated grantees, excluding the grantees named as plaintiffs in already pending actions brought to  challenge HHS’s termination of TPPP grants.    46.  Excluded from the class are the plaintiffs in the following pending actions: Policy  and Research, LLC, v. HHS, No. 18-cv-346-KBJ (D.D.C.), Planned Parenthood of Greater  Washington and Northern Idaho v. HHS, No. 2:18-cv-00055 (E.D. Wash.), King County v. Azar,  No. 18-cv-00242 (W.D. Wash.), and Healthy Teen Network v. Azar, No. 18-cv-00468 (D. Md.).   47.  The class satisfies the requirements of Federal Rules of Civil Procedure 23(a) and  23(b)(2).   48.  The class includes more than 60 members and is so numerous that joinder of all  members is impracticable.    49.  Questions of law and fact are common to the class, including, without limitation,  whether HHS’s shortening of the TPPP grant periods violated HHS regulations and the APA.   50.  The claims of the named plaintiff are typical of the claims of the class because,  among other things, all class members were comparably injured by defendants’ unlawful  termination of their grants, as described above.    51.  The named plaintiff is an adequate representative of the class because its interests  do not conflict with the interest of the class it seeks to represent; it has retained counsel who are  competent and experienced in litigation; and because it intends to prosecute this action vigorously.  Named plaintiff is represented by counsel who have knowledge and familiarity with the relevant  law concerning the TPPP program, the APA, and class actions.   53.  The APA authorizes this Court to hold unlawful and set aside final agency action  that is “arbitrary, capricious, an abuse of discretion, or otherwise not in accordance with law.” 