70.  Plaintiffs bring Counts 1-4 and 6 of this action as a class action pursuant to  Federal Rule of Civil Procedure 23, on behalf of themselves and all other similarly situated  persons.  This class includes:   All Iranian refugees who (1) applied for refugee admission to the  United States under the Lautenberg Amendment, whether as a  principal applicant or derivative relatives; (2) traveled to Vienna,  Austria, for processing; and (3) received denials from the United  States government in or after February 2018 with the sole  explanation that their application was denied “as a matter of  discretion,” and their U.S.-based Close Family Members who  served as their U.S. ties.   71.  “Close Family Member” as used in the class definition is defined as parents,  parents-in-law, spouses, fiancés, children, adult sons or daughters, sons-in-law, daughters-in-law,  siblings (whole or half), and step-relationships, grandparents, grandchildren, brothers-in-law,  sisters-in-law, aunts, uncles, nieces, nephews, and cousins.    72.  Separate subclasses may be appropriate for the proposed class defined above.    73.  Joinder is impracticable not only because the proposed class is so numerous, but  also because many members of the proposed class are currently in Vienna, Austria and are both  physically and financially unable to access the U.S. court system to pursue an action on their  own.     74.  The members of the proposed class share common issues of fact and law,  including but not limited to:  (1) whether the Notices of Ineligibility denying refugee status “as a  matter of discretion” violate the Lautenberg and Specter Amendments, the Administrative  Procedure Act, and the Accardi doctrine; (2) whether relief is available under those provisions  and the Mandamus Act; and (3) whether the undisclosed program change violated the  Administrative Procedure Act.    75.  The claims or defenses of the named Plaintiffs are typical of the claims or  defenses of members of the proposed class.    78.  Plaintiffs re-allege and incorporate by reference herein each and every allegation  contained in paragraphs 1 through 77 above.    79.  An actual controversy exists between the parties, because the Defendants seek to  rely upon the Notices of Ineligibility issued to Plaintiffs and Plaintiffs seek a determination that  those Notices of Ineligibility are invalid and unlawful.    80.  For the reasons stated herein and pursuant to 28 U.S.C. § 2201-02, Plaintiffs ask  the Court to declare that the Notices of Ineligibility issued to them were unlawful.  81.  Plaintiffs re-allege and incorporate by reference herein each and every allegation  contained in paragraphs 1 through 80 above.   82.  Each of the Notices of Ineligibility issued to Plaintiffs is a final agency action that  violates the Lautenberg Amendment.  8 U.S.C. § 1157 (note).   83.  The Notices should therefore be set aside as unlawful under 5 U.S.C. § 702 and 5  85.  Plaintiffs re-allege and incorporate by reference herein each and every allegation  contained in paragraphs 1 through 84 above.   86.  Each of the Notices of Ineligibility issued to Plaintiffs is a final agency action that  violate agency procedures, including those at 8 C.F.R. § 103.2(b)(16).    87.  The Notices should therefore be set aside under the principle articulated in United  States ex. rel. Accardi v. Shaughnessy, 347 U.S. 260 (1954).    88.  The Notices should also be set aside as unlawful under 5 U.S.C. § 702 and 5  A.  Congress Passed the Lautenberg and Specter Amendments to Facilitate  Refugee Admissions Of Persecuted Religious Minorities   ACCARDI DOCTRINE & ADMINISTRATIVE PROCEDURE ACT  (On Behalf of All Plaintiffs, Including the Class, Against DHS Defendants)   DECLARATORY JUDGMENT   (On Behalf of All Plaintiffs, Including the Class, Against All Defendants)   LAUTENBERG AMENDMENT & ADMINISTRATIVE PROCEDURE ACT    (On Behalf of All Plaintiffs, including the Class, Against DHS Defendants)  