39.  Representative Plaintiffs Brazile, Mote, and Motes bring this action against  Defendant PRCA under Rule 23(a) and (b)(2) of the Federal Rules of Civil Procedure on behalf  of all members of the following Class (collectively, the “Class”):  “All present and future professional rodeo athletes who are or will  be an officer, board member, employee of ERA or have or will  have an ownership or financial interest of any form in ERA.”      42.  By engaging in this unlawful conduct, PRCA has acted and/or refused to  act on grounds that apply generally to representative Plaintiffs Brazile, Mote, Motes, and all  members of the Class.  Temporary and final injunctive relief or corresponding declaratory relief,  therefore, is appropriate respecting the Class as a whole   43.  The claims of representative Plaintiffs Brazile, Mote, and Motes are typical  of the claims of all members of the Class and these representative Plaintiffs will fairly and  adequately protect the interests of the Class.  Representative Plaintiffs Brazile, Mote, and Motes  as well as other members of the Class have been injured by the same unlawful and  anticompetitive conduct engaged in by the PRCA.  Representative Plaintiffs Brazile, Mote, and  Motes’ interests are consistent with, and not antagonistic to, those of the other members of the  Class.   44.  Representative Plaintiffs are represented by counsel who are competent and  experienced in the prosecution of class action and antitrust litigation against sports organizations.    45.  Representative Plaintiffs Brazile, Mote, and Motes will fairly and  adequately protect the interests of the Class.   46.  The Class is readily definable.  