12.  Plaintiffs bring this action pursuant to Rule 23 of the Federal Rules  of Civil Procedure, on behalf of the class defined as follows: all past and current  employees of defendant FCA who were dues paying members of the UAW  impacted by the illegal, improper, and collusive conduct of FCA and the UAW  in violation of the LMRA.   13.  The members of the class are so numerous that joinder is  impractical, if not impossible.   14.  The members of the class can be identified easily through a review  of the business records of FCA and the UAW.   15.  There are common questions of fact and law affecting all class  members that arise as a result of the allegations in this complaint.   17.  Plaintiffs will fairly and adequately protect the interests of the  proposed class as they are injured employees of FCA and injured members of  the UAW.    18.  A class action is a superior method of resolution to the other  available methods for a fair, efficient, and just resolution of this controversy.   19.  The expense and burden of individual litigation are impediments to  class members’ seeking relief for the wrongful conduct alleged.   20.  This action is maintainable under Rule 23(b)(3) of the Federal Rules  of Civil Procedure because common questions of fact and law predominate over  questions affecting only individual class members (individual questions focus  almost exclusively on the amount of damages owed in the form of dues paid by  the class members, and other compensation, including compensatory damages,  punitive damages, and interest).   21.  The amount in controversy with respect to each individual member  of the class is relatively modest when compared to the costly prosecution of  separate actions.   66.  Plaintiffs incorporate the preceding paragraphs by reference.   67.  FCA unlawfully paid bribes to executives of the UAW to take FCA- friendly positions during collecting bargaining negotiations, including those in  2011 and 2015.   69.  FCA, through the acts of its designated agents, who included  officers, directors, senior managers, and executives, knowingly and voluntarily  joined the conspiracy.   70.  Members of the conspiracy made prohibited payments with the  intention of impermissibly influencing the collective bargaining process.   71.  The prohibited payments did impermissibly influence the collective  bargaining process by allowing FCA to obtain company-friendly concessions  from the UAW during the collective bargaining process.   72.  The prohibited payments caused at least one designated agent of the  UAW, a co-conspirator with FCA, to direct and/or impermissibly influence the  decision of the UAW Executive Board to expend billions of dollars in the non- arm’s length purchase of an equity interest in FCA.   73.  As a result of FCA’s violation of the LMRA, plaintiffs and other  class members have been harmed in that potentially hundreds of millions of  dollars of their dues paid to the UAW for the purposes of good-faith negotiations  have instead been spent on tainted and/or illegal collective bargaining  negotiations.   75.  Plaintiffs incorporate the preceding paragraphs by reference.   76.  The UAW engaged in willfully requesting, receiving, accepting, and  agreeing to receive and accept, money and things of value from persons acting  in the interest of FCA.   77.  The UAW gave authority to its designated agents, including  Holiefield and King, among others, to represent its members who were  employees of FCA.   78.  The UAW had an obligation to serve the interests of all members  without favoritism to the company, and/or without favoritism or hostility to any  members, to exercise its representational discretion with complete good faith  and honesty, and to avoid arbitrary conduct.   79.  The UAW breached its duty to its membership, by acting based  upon the improper motivation of FCA’s bribery, and the UAW’s requesting and  receiving prohibited payments and things of value.   80.  The UAW’s representation of its membership was arbitrary,  perfunctory, or inexcusably neglectful.   82.  By its involvement in the FCA/UAW conspiracy, the UAW,  through its designated agents, lacked a rational basis for decision-making when  it chose to expend millions of dollars of its members’ dues in the tainted  bargaining process.   83.  By its involvement in the conspiracy, the UAW, through its  designated agents, lacked a rational basis for decision making and acted  egregiously neglectful when it expended billions of dollars of its membership’s  dues on a non-arm’s length purchase of an equity interest in FCA.   84.  By the multiple UAW actors in the FCA conspiracy, the UAW  failed in its duty to investigate the actions of its designated agents, to the  detriment of its members’ rights, and to the expense of its membership through  hundreds of millions of dollars of dues having been wasted on tainted  bargaining.   BREACH OF THE DUTY OF   FAIR REPRESENTATION UNDER THE LMRA    VIOLATION OF THE   LABOR MANAGEMENT RELATIONS ACT   