76.  Pursuant to Rules 23(a), (b)(2), and (b)(3) of the Federal Rules of  Civil Procedure, Plaintiff brings this Action on behalf of himself, the Nationwide  Class, and State Classes, defined as follows:   Nationwide Class: All persons or entities in the United States (including its  territories and the District of Columbia) who purchased or leased a “Class  Vehicle.”     77.  In addition to the Nationwide class, and pursuant to Federal Rules of  Civil Procedure Rule 23(c)(5), Plaintiff seeks to represent the following State  Classes as well as any subclasses or issue classes as Plaintiff may propose and/or  the Court may designate at the time of class certification:  Michigan Class:  All persons or entities in the State of Michigan who  purchased or leased a “Class Vehicle.”    New Jersey Class: All persons or entities in the State of New Jersey who  purchased or leased a “Class Vehicle.”     A.  Defendants’ emission-related problems are familiar. ....................... 16  B.  Testing Reveals Emissions Problems With the Class  Vehicles ............................................................................................. 19  C.  A Key Component of the Class Vehicles’ Emissions  System—The Catalytic Converter .................................................... 20  D.  Injury to Consumers .......................................................................... 24  VI.  A.   Class Definitions   A.  Class Definitions ............................................................................... 30  B.  Class Certification Requirements ...................................................... 32  IMPLIED AND WRITTEN WARRANTY  Magnuson - Moss Warranty Act (15 U.S.C. §§ 2301, et seq.)  101. Plaintiff incorporates by reference all preceding allegations as though  fully set forth herein.    102. Plaintiff brings this Action on behalf of himself and the Nationwide  Class against Defendants.  103. This Court has jurisdiction to decide claims brought under 15 U.S.C.  § 2301 by virtue of 28 U.S.C. § 1332 (a)-(d).  104. Plaintiff and members of the Class are “consumers” within the  meaning of 15 U.S.C. § 2301(3).  105. Defendants are a “supplier” and “warrantor” within the meaning of 15  U.S.C. § 2301(4) and (5), respectively.  106. The Class Vehicles are “consumer products” within the meaning of  SEATTLE, WA 98101-3052  T E L E P H O N E :  ( 2 0 6 )  6 2 3 - 1 9 0 0   F A C S I M I L E :  ( 2 0 6 )  6 2 3 - 3 3 8 4   X. 