41. Plaintiffs bring this case as a class action pursuant to Federal Rules of Civil Procedure 23(b)(1)(A) and (b)(2), and, alternatively, 23(b)(3), for themselves and for all others  similarly situated, and any subclasses deemed appropriate by this Court. The class consists of all  individuals: 1) who are Washington State employees exclusively represented by WFSE as  described in paragraph 9 above; 2) from whom the State continues to deduct union dues/fees on  behalf of WFSE since the U.S. Supreme Court issued Janus v. AFSCME on June 27, 2018; and  3) who have not clearly and affirmatively consented to dues/fees deductions by waiving the constitutional right to not fund union advocacy on or after June 27, 2018.  The class includes  everyone who comes within the class definition at any time from three years prior to the  commencement of this action until the conclusion of this action.    42. Upon information and belief, there are hundreds, and likely thousands, of class members. Their number is so numerous and in varying locations and jurisdictions across  Washington that joinder is impractical.  