title: Class action

text: The oldest predecessor to the class-action rule in the United States was in the Federal Equity Rules, specifically Equity Rule 48, promulgated in 1842.


title: Class action

text: Where the parties on either side are very numerous, and cannot, without manifest inconvenience and oppressive delays in the suit, be all brought before it, the court in its discretion may dispense with making all of them parties, and may proceed in the suit, having sufficient parties before it to represent all the adverse interests of the plaintiffs and the defendants in the suit properly before it. But in such cases, the decree shall be without prejudice to the rights and claims of all the absent parties.


title: Class action

text: This allowed for representative suits in situations where there were too many individual parties (which now forms the first requirement for class-action litigation – numerosity). However, this rule did not allow such suits to bind similarly situated absent parties, which rendered the rule ineffective. Within ten years, the Supreme Court interpreted Rule 48 in such a way so that it could apply to absent parties under certain circumstances, but only by ignoring the plain meaning of the rule. In the rules published in 1912, Equity Rule 48 was replaced with Equity Rule 38 as part of a major restructuring of the Equity Rules, and when federal courts merged their legal and equitable procedural systems in 1938, Equity Rule 38 became Rule 23 of the Federal Rules of Civil Procedure.


title: Class action

text: A major revision of the FRCP in 1966 radically transformed Rule 23, made the opt-out class action the standard option, and gave birth to the modern class action. Entire treatises have been written since to summarize the huge mass of law that sprang up from the 1966 revision of Rule 23. Just as medieval group litigation bound all members of the group regardless of whether they all actually appeared in court, the modern class action binds "all" members of the class, except for those who choose to opt-out (if the rules permit them to do so).


title: Class action

text: The Advisory Committee that drafted the new Rule 23 in the mid-1960s was influenced by two major developments. First was the suggestion of Harry Kalven, Jr. and Maurice Rosenfield in 1941 that class-action litigation by individual shareholders on behalf of all shareholders of a company could effectively supplement direct government regulation of securities markets and other similar markets. The second development was the rise of the civil rights movement, environmentalism and consumerism. The groups behind these movements, as well as many others in the 1960s, 1970s and 1980s, all turned to class actions as a means for achieving their goals. For example, a 1978 environmental law treatise reprinted the "entire" text of Rule 23 and mentioned "class actions" 14 times in its index.


title: Class action

text: Businesses targeted by class actions for inflicting massive aggregate harm have sought ways to avoid class actions altogether. In the 1990s, the US Supreme Court issued several decisions that strengthened the "federal policy favoring arbitration". In response, lawyers have added provisions to consumer contracts of adhesion called "collective action waivers", which prohibit those signing the contracts from bringing class-action suits. In 2011, the US Supreme Court ruled in a 5–4 decision in "AT&T Mobility v. Concepcion" that the Federal Arbitration Act of 1925 preempts state laws that prohibit contracts from disallowing class-action lawsuits, which will make it more difficult for consumers to file class-action lawsuits. The dissent pointed to a saving clause in the federal act which allowed states to determine how a contract or its clauses may be revoked.


title: Class action

text: In two major 21st-century cases, the Supreme Court ruled 5–4 against certification of class actions due to differences in each individual members' circumstances: first in "Wal-Mart v. Dukes" (2011) and later in "Comcast Corp. v. Behrend" (2013).


title: Class action

text: Companies may insert the phrase "may elect to resolve any claim by individual arbitration" into their consumer and employment contracts to use arbitration and prevent class-action lawsuits.


title: Class action

text: Rejecting arguments that they violated employees’ rights to collective bargaining, and that modestly-valued consumer claims would be more efficiently litigated within the parameters of one lawsuit, the U. S. Supreme Court, in "Epic Systems Corp. v. Lewis" (2018), sanctioned the use of so-called "class action waivers". Citing its deference to freedom to contract principles, the Epic Systems opinion opened the door dramatically to the use of these waivers as a condition of employment, consumer purchases and the like. Some commentators in opposition to the ruling see it as a "death knell" to many employment and consumer class actions, and have increasingly pushed for legislation to circumvent it in hopes of reviving otherwise-underrepresented parties’ ability to litigate on a group basis. Supporters (mostly pro-business) of the high court's ruling argue its holding is consistent with private contract principles. Many of those supporters had long-since argued that class action procedures were generally inconsistent with due process mandates and unnecessarily promoted litigation of otherwise small claims—thus heralding the ruling's anti-litigation effect.


title: Class action

text: In 2017, the US Supreme Court issued its opinion in Bristol-Meyer Squibb Co. v. Superior Court of California, 137 S. Ct. 1773 (2017), holding that over five hundred plaintiffs from other states cannot bring a consolidated mass action against the pharmaceutical giant in the State of California. This opinion may arguably render nationwide mass action and class action impossible in any single state besides the defendant's home state.


title: Class action

text: In 2020, the 11th Circuit Court of Appeals found incentive awards are impermissible. Incentive awards are a relatively modest payment made to class representatives as part of a class settlement. The ruling was a response to an objector who claimed Rule 23 required that the fee petition be filed "before" the time frame for class member objections to be filed; and payments to the class representative violates doctrine from two US Supreme Court cases from the 1800s.


title: Class action

text: As of 2010, there was no publicly maintained list of nonsecurities class-action settlements, although a securities class-action database exists in the Stanford Law School Securities Class Action Clearinghouse and several for-profit companies maintain lists of the securities settlements. One study of federal settlements required the researcher to manually search databases of lawsuits for the relevant records, although state class actions were not included due to the difficulty in gathering the information. Another source of data is US Bureau of Justice Statistics "Civil Justice Survey of State Courts", which offers statistics for the year 2005.


title: Class action

text: Proponents of class actions state that they offer a number of advantages because they aggregate many individualized claims into one representational lawsuit.


title: Class action

text: First, aggregation can increase the efficiency of the legal process, and lower the costs of litigation. In cases with common questions of law and fact, aggregation of claims into a class action may avoid the necessity of repeating "days of the same witnesses, exhibits and issues from trial to trial". "Jenkins v. Raymark Indus. Inc.", 782 F.2d 468, 473 (5th Cir. 1986) (granting certification of a class action involving asbestos).


title: Class action

text: Second, a class action may overcome "the problem that small recoveries do not provide the incentive for any individual to bring a solo action prosecuting his or her rights". "Amchem Prods., Inc. v. Windsor", 521 U.S. 591, 617 (1997) (quoting "Mace v. Van Ru Credit Corp.", 109 F.3d 388, 344 (7th Cir. 1997)). "A class action solves this problem by aggregating the relatively paltry potential recoveries into something worth someone's (usually an attorney's) labor." "Amchem Prods., Inc.", 521 U.S. at 617 (quoting "Mace", 109 F.3d at 344). In other words, a class action ensures that a defendant who engages in widespread harmbut does so minimally against each individual plaintiffmust compensate those individuals for their injuries. For example, thousands of shareholders of a public company may have losses too small to justify separate lawsuits, but a class action can be brought efficiently on behalf of all shareholders. Perhaps even more important than compensation is that class treatment of claims may be the only way to impose the costs of wrongdoing on the wrongdoer, thus deterring future wrongdoing.


title: Class action

text: Third, class-action cases may be brought to purposely change behavior of a class of which the defendant is a member. "Landeros v. Flood" (1976) was a landmark case decided by the California Supreme Court that aimed at purposefully changing the behavior of doctors, encouraging them to report suspected child abuse. Otherwise, they would face the threat of civil action for damages in tort proximately flowing from the failure to report the suspected injuries. Previously, many physicians had remained reluctant to report cases of apparent child abuse, despite existing law that required it.


title: Class action

text: Fourth, in "limited fund" cases, a class action ensures that all plaintiffs receive relief and that early-filing plaintiffs do not raid the fund (i.e., the defendant) of all its assets before other plaintiffs may be compensated. See "Ortiz v. Fibreboard Corp.", 527 U.S. 815 (1999). A class action in such a situation centralizes all claims into one venue where a court can equitably divide the assets amongst all the plaintiffs if they win the case.


title: Class action

text: Finally, a class action avoids the situation where different court rulings could create "incompatible standards" of conduct for the defendant to follow. See Fed. R. Civ. P. 23(b)(1)(A). For example, a court might certify a case for class treatment where a number of individual bond-holders sue to determine whether they may convert their bonds to common stock. Refusing to litigate the case in one trial could result in different outcomes and inconsistent standards of conduct for the defendant corporation. Thus, courts will generally allow a class action in such a situation. See, e.g., "Van Gemert v. Boeing Co.", 259 F. Supp. 125 (S.D.N.Y. 1966).


title: Class action

text: Whether a class action is superior to individual litigation depends on the case and is determined by the judge's ruling on a motion for class certification. The Advisory Committee Note to Rule 23, for example, states that mass torts are ordinarily "not appropriate" for class treatment. Class treatment may not improve the efficiency of a mass tort because the claims frequently involve individualized issues of law and fact that will have to be re-tried on an individual basis. See "Castano v. Am. Tobacco Co.", 84 F.3d 734 (5th Cir. 1996) (rejecting nationwide class action against tobacco companies). Mass torts also involve high individual damage awards; thus, the absence of class treatment will not impede the ability of individual claimants to seek justice. Other cases, however, may be more conducive to class treatment.


title: Class action

text: Class-action lawsuits are an important and valuable part of the legal system when they permit the fair and efficient resolution of legitimate claims of numerous parties by allowing the claims to be aggregated into a single action against a defendant that has allegedly caused harm.


title: Class action

text: There are several criticisms of class actions. The preamble to the Class Action Fairness Act stated that some abusive class actions harmed class members with legitimate claims and defendants that have acted responsibly, adversely affected interstate commerce, and undermined public respect for the country's judicial system.


title: Class action

text: Class members often receive little or no benefit from class actions. Examples cited for this include large fees for the attorneys, while leaving class members with coupons or other awards of little or no value; unjustified awards are made to certain plaintiffs at the expense of other class members; and confusing notices are published that prevent class members from being able to fully understand and effectively exercise their rights.


title: Class action

text: For example, in the United States, class lawsuits sometimes bind all class members with a low settlement. These "coupon settlements" (which usually allow the plaintiffs to receive a small benefit such as a small check or a coupon for future services or products with the defendant company) are a way for a defendant to forestall major liability by precluding many people from litigating their claims separately, to recover reasonable compensation for the damages. However, existing law requires judicial approval of all class-action settlements, and in most cases, class members are given a chance to opt out of class settlement, though class members, despite opt-out notices, may be unaware of their right to opt-out because they did not receive the notice, did not read it or did not understand it.


title: Class action

text: The Class Action Fairness Act of 2005 addresses these concerns. An independent expert may scrutinize coupon settlements before judicial approval in order to ensure that the settlement will be of value to the class members (28 U.S.C.A. 1712(d)). Further, if the action provides for settlement in coupons, "the portion of any attorney's fee award to class counsel that is attributable to the award of the coupons shall be based on the value to class members of the coupons that are redeemed". 28 U.S.C.A. 1712(a).


title: Class action

text: Class action cases present significant ethical challenges. Defendants can hold reverse auctions and any of several parties can engage in collusive settlement discussions. Subclasses may have interests that diverge greatly from the class but may be treated the same. Proposed settlements could offer some groups (such as former customers) much greater benefits than others. In one paper presented at an ABA conference on class actions in 2007, authors commented that "competing cases can also provide opportunities for collusive settlement discussions and reverse auctions by defendants anxious to resolve their new exposure at the most economic cost".


title: Class action

text: Although normally plaintiffs are the class, defendant class actions are also possible. For example, in 2005, the Roman Catholic Archdiocese of Portland in Oregon was sued as part of the Catholic priest sex-abuse scandal. All parishioners of the Archdiocese's churches were cited as a defendant class. This was done to include their assets (local churches) in any settlement. Where both the plaintiffs and the defendants have been organized into court-approved classes, the action is called a bilateral class action.


title: Class action

text: In a class action, the plaintiff seeks court approval to litigate on behalf of a group of similarly situated persons. Not every plaintiff looks for or could obtain such approval. As a procedural alternative, plaintiff's counsel may attempt to sign up every similarly situated person that counsel can find as a client. Plaintiff's counsel can then join the claims of all of these persons in one complaint, a so-called "mass action", hoping to have the same efficiencies and economic leverage as if a class had been certified.


title: Class action

text: Because mass actions operate outside the detailed procedures laid out for class actions, they can pose special difficulties for both plaintiffs, defendants, and the court. For example, settlement of class actions follows a predictable path of negotiation with class counsel and representatives, court scrutiny, and notice. There may not be a way to uniformly settle all of the many claims brought via a mass action. Some states permit plaintiff's counsel to settle for all the mass action plaintiffs according to a majority vote, for example. Other states, such as New Jersey, require each plaintiff to approve the settlement of that plaintiff's own individual claims.


title: Class action

text: Class actions became part of the Australian legal landscape only when the Federal Parliament amended the Federal Court of Australia Act ("the FCAA") in 1992 to introduce the "representative proceedings", the equivalent of the American "class actions".


title: Class action

text: Likewise, class actions appeared slowly in the New Zealand legal system. However, a group can bring litigation through the action of a representative under the High Court Rules which provide that one or a multitude of persons may sue on behalf of, or for the benefit of, all persons "with the same interest in the subject matter of a proceeding". The presence and expansion of litigation funders have been playing a significant role in the emergence of class actions in New Zealand. For example, the "Fair Play on Fees" proceedings in relation to penalty fees charged by banks were funded by Litigation Lending Services (LLS), a company specializing in the funding and management of litigation in Australia and New Zealand. It was the biggest class-action suit in New Zealand history.


title: Class action

text: The Austrian Code of Civil Procedure ("Zivilprozessordnung" – ZPO) does not provide for a special proceeding for complex class-action litigation. However, Austrian consumer organizations ("Verein für Konsumenteninformation" (VKI) and the Federal Chamber of Labour / "Bundesarbeitskammer") have brought claims on behalf of hundreds or even thousands of consumers. In these cases, the individual consumers assigned their claims to one entity, who has then brought an ordinary (two-party) lawsuit over the assigned claims. The monetary benefits were redistributed among the class. This technique, labeled as "class action Austrian style," allows for a significant reduction of overall costs. The Austrian Supreme Court, in a judgment, confirmed the legal admissibility of these lawsuits under the condition that all claims are essentially based on the same grounds.


title: Class action

text: The Austrian Parliament unanimously requested the Austrian Federal Minister for Justice to examine the possibility of new legislation providing for a cost-effective and appropriate way to deal with mass claims. Together with the Austrian Ministry for Social Security, Generations and Consumer Protection, the Justice Ministry opened the discussion with a conference held in Vienna in June 2005. With the aid of a group of experts from many fields, the Justice Ministry began drafting the new law in September 2005. With the individual positions varying greatly, a political consensus could not be reached.


title: Class action

text: Provincial laws in Canada allow class actions. All provinces permit plaintiff classes and some permit defendant classes. Quebec was the first province to enact class proceedings legislation, in 1978. Ontario was next, with the Class Proceedings Act, 1992. As of 2008, 9 of 10 provinces had enacted comprehensive class actions legislation. In Prince Edward Island, where no comprehensive legislation exists, following the decision of the Supreme Court of Canada in "Western Canadian Shopping Centres Inc. v. Dutton", [2001] 2 S.C.R. 534, class actions may be advanced under a local rule of court. The Federal Court of Canada permits class actions under Part V.1 of the Federal Courts Rules.


title: Class action

text: Legislation in Saskatchewan, Manitoba, Ontario, and Nova Scotia expressly or by judicial opinion has been read to allow for what are informally known as national "opt-out" class actions, whereby residents of other provinces may be included in the class definition and potentially be bound by the court's judgment on common issues unless they opt-out in a prescribed manner and time. Court rulings have determined that this permits a court in one province to include residents of other provinces in the class action on an "opt-out" basis.


title: Class action

text: Judicial opinions have indicated that provincial legislative national opt-out powers should not be exercised to interfere with the ability of another province to certify a parallel class action for residents of other provinces. The first court to certify will generally exclude residents of provinces whose courts have certified a parallel class action. However, in the Vioxx litigation, two provincial courts certified overlapping class actions whereby Canadian residents were class members in two class actions in two provinces. Both decisions are under appeal.


title: Class action

text: The largest class action suit in Canada was settled in 2005 after Nora Bernard initiated efforts that led to an estimated 79,000 survivors of Canada's residential school system suing the Canadian government. The settlement amounted to upwards of $5 billion.


title: Class action

text: Chile approved class actions in 2004. The Chilean model is technically an opt-out issue class action, followed by a compensatory stage which can be collective or individual. This means that the class action is designed to declare the defendant generally liable with "erga omnes" effects if and only if the defendant is found liable, and the declaratory judgment can be used then to pursue damages in the same procedure or in individual ones in different jurisdictions. If the latter is the case, the liability cannot be discussed, but only the damages. There under the Chilean procedural rules, one particular case works as an opt-out class action for damages. This is the case when defendants can identify and compensate consumers directly, i.e. because it is their banking institution. In such cases, the judge can skip the compensatory stage and order redress directly. Since 2005 more than 100 cases have been filed, mostly by "Servicio Nacional del Consumidor" [SERNAC], the Chilean consumer protection agency. Salient cases have been "Condecus v. BancoEstado" and "SERNAC v. La Polar".


title: Class action

text: Under French law, an association can represent the collective interests of consumers; however, each claimant must be individually named in the lawsuit. On January 4, 2005, President Chirac urged changes that would provide greater consumer protection. A draft bill was proposed in April 2006 but did not pass.


title: Class action

text: Following the change of majority in France in 2012, the new government proposed introducing class actions into French law. The project of "loi Hamon" of May 2013 aimed to limit the class action to consumer and competition disputes. The law was passed on March 1, 2014.


title: Class action

text: Class actions are generally not permitted in Germany, as German law does not recognize the concept of a targeted class being affected by certain actions. This requires each plaintiff to individually prove that they were affected by an action, and present their individual damages, and prove the causality between both parties.


title: Class action

text: Joint litigation () is a legal act that may permit plaintiffs that are in the same legal community with respect to the dispute, or are entitled by the same factual or legal reason. These are not typically regarded as class action suits, as each individual plaintiff is entitled to compensation for their individual, incurred damages and not as a result of being a member of a class.


title: Class action

text: The combination of court cases () is another method that permits a judge to combine multiple separate court cases into a single trial with a single verdict. According to § 147 ZPO, this is only permissible if all cases are regarding the same factual and legal event and basis.


title: Class action

text: A genuine extension of the legal effect of a court decision beyond the parties involved in the proceedings is offered under corporate law. This procedure applies to the review of stock payoffs under "Stock Corporation Act" ("Aktiengesetz". Pursuant to Sec. 13 Sentence 2 "Mediation Procedure Act" ("Spruchverfahrensgesetz" ), the court decision concerning the dismissal or direction of a binding arrangement of an adequate compensation is effective for and against all shareholders, including those who have already agreed to a previous settlement in this matter.


title: Class action

text: The "Capital Investor Model Case Act" ("Kapitalanleger-Musterverfahrensgesetz") is an attempt to enable model cases to be brought by a large number of potentially affected parties in the event of disputes, limited to the investment market. In contrast to the US class actions, each affected party must file a lawsuit in its own name in order to participate in the model proceedings.


title: Class action

text: Effective on November 1, 2018, the Code of Civil Procedure (Zivilprozessordnung) introduced the Model Declaratory Action (§ 606 ZPO) that created the ability to bundle similar claims by many affected parties efficiently into one proceeding.


title: Class action

text: Registered Consumer Protection Associations can file – if they represent at least 10 individuals – for a (general) judicial finding whether the factual and legal requirements for of claims or legal relationships are met or not. These individuals have to register in order to inhibit their claims. Since these Adjudications are more of a general nature, each individual must assert their claims in their own court proceedings. The competent court is bound by the Model Declaratory Action decision.


title: Class action

text: German law also recognizes the "Associative Action" ("Verbandklage"), which is comparable to the class action and is predominantly used in environmental law. In civil law, the "Associative Action" is represented by a foreign body in the matter of asserting and enforcing individual claims and the claimant can no longer control the proceedings.


title: Class action

text: Class actions can be brought by Germans in the US for events in Germany if the facts of the case relate to the US. For example, in the case of the Eschede train disaster, the lawsuit was allowed because several aggrieved parties came from the US and had purchased rail tickets there.


title: Class action

text: Decisions of the Indian Supreme Court in the 1980s loosened strict "locus standi" requirements to permit the filing of suits on behalf of rights of deprived sections of society by public-minded individuals or bodies. Although not strictly "class action litigation" as it is understood in American law, Public Interest Litigation arose out of the wide powers of judicial review granted to the Supreme Court of India and the various High Courts under and Article 226 of the Constitution of India. The sort of remedies sought from courts in Public Interest Litigation go beyond mere award of damages to all affected groups, and have sometimes (controversially) gone on to include Court monitoring of the implementation of legislation and even the framing of guidelines in the absence of Parliamentary legislation.


title: Class action

text: However, this innovative jurisprudence did not help the victims of the Bhopal gas tragedy, who were unable to fully prosecute a class-action litigation (as understood in the American sense) against Union Carbide due to procedural rules that would make such litigation impossible to conclude and unwieldy to carry out. Instead, the Government of India exercised its right of "parens patriae" to appropriate all the claims of the victims and proceeded to litigate on their behalf, first in the New York courts and later, in the Indian courts. Ultimately, the matter was settled between the Union of India and Union Carbide (in a settlement overseen by the Supreme Court of India) for a sum of as a complete settlement of all claims of all victims for all time to come.


title: Class action

text: Public interest litigation has now broadened in scope to cover larger and larger groups of citizens who may be affected by government inaction. Examples of this trend include the conversion of all public transport in the city of Delhi from diesel engines to CNG engines on the basis of the orders of the Delhi High Court; the monitoring of forest use by the High Courts and the Supreme Court to ensure that there is no unjustified loss of forest cover; and the directions mandating the disclosure of assets of electoral candidates for the Houses of Parliament and State Assembly.


title: Class action

text: The Supreme Court has observed that the PIL has tended to become a means to gain publicity or obtain relief contrary to constitutionally valid legislation and policy. Observers point out that many High Courts and certain Supreme Court judges are reluctant to entertain PILs filed by non-governmental organizations and activists, citing concerns of separation of powers and parliamentary sovereignty.


title: Class action

text: In Irish law, there is no such thing as a "class action" per se. Third-party litigation funding is prohibited under Irish law. Instead, there is the 'representative action' () or 'test case' ("cás samplach"). A representative action is "where one claimant or defendant, with the same interest as a group of claimants or defendants in an action, institutes or defends proceedings on behalf of that group of claimants or defendants."


title: Class action

text: Italy has class action legislation. Consumer associations can file claims on behalf of groups of consumers to obtain judicial orders against corporations that cause injury or damage to consumers. These types of claims are increasing, and Italian courts have allowed them against banks that continue to apply compound interest on retail clients' current account overdrafts. The introduction of class actions is on the government's agenda. On November 19, 2007, the Senato della Repubblica passed a class-action law in Finanziaria 2008, a financial document for the economy management of the government. From 10 December 2007, in order of Italian legislation system, the law is before the House and has to be passed also by the Camera dei Deputati, the second house of Italian Parliament, to become an effective law. In 2004, the Italian parliament considered the introduction of a type of class action, specifically in the area of consumer law. No such law has been enacted, but scholars demonstrated that class actions ("azioni rappresentative") do not contrast with Italian principles of civil procedure. Class action is regulated by art. 140 bis of the Italian consumers' code and has been in force since 1 July 2009. On May 19, 2021, the reform of the Italian legal framework on class actions finally entered into force. The new rules, designed by Law n. 31 and published on April 18, 2019, (Law n. 31/2019), were initially intended to become effective on April 19, 2020, but had been delayed twice. The new rules on class actions are now included in the Italian Civil Procedure Code (ICPC). Overall, the new class action appears to be a viable instrument which, through a system of economic incentives, could overcome the rational apathy of small-claims holders and ensure redress.


title: Class action

text: Dutch law allows associations ("verenigingen") and foundations ("stichtingen") to bring a so-called collective action on behalf of other persons, provided they can represent the interests of such persons according to their by-laws ("statuten") (section 3:305a Dutch Civil Code). All types of actions are permitted. This includes a claim for monetary damages, provided the event occurred after 15 November 2016 (pursuant to new legislation which entered into force 1 January 2020). Most class actions over the past decade have been in the field of securities fraud and financial services. The acting association or foundation may come to a collective settlement with the defendant. The settlement may also include – and usually primarily consists of – monetary compensation of damages. Such settlement can be declared binding for all injured parties by the Amsterdam Court of Appeal (section 7:907 Dutch Civil Code). The injured parties have an opt-out right during the opt-out period set by the Court, usually 3 to 6 months. Settlements involving injured parties from outside The Netherlands can also be declared binding by the Court. Since US courts are reluctant to take up class actions brought on behalf of injured parties not residing in the US who have suffered damages due to acts or omissions committed outside the US, combinations of US class actions and Dutch collective actions may come to a settlement that covers plaintiffs worldwide. An example of this is the Royal Dutch Shell Oil Reserves Settlement that was declared binding upon both US and non-US plaintiffs.


title: Class action

text: "Pozew zbiorowy" or class action has been allowed under Polish law since July 19, 2010. A minimum of 10 persons, suing based on the same law, is required.


title: Class action

text: Collective litigation has been allowed under Russian law since 2002. Basic criteria are, like in the US, numerosity, commonality, and typicality.


title: Class action

text: Spanish law allows nominated consumer associations to take action to protect the interests of consumers. A number of groups already have the power to bring collective or class actions: certain consumer associations, bodies legally constituted to defend the "collective interest" and groups of injured parties.


title: Class action

text: Recent changes to Spanish civil procedure rules include the introduction of a quasi-class action right for certain consumer associations to claim damages on behalf of unidentified classes of consumers. The rules require consumer associations to represent an adequate number of affected parties who have suffered the same harm. Also, any judgment made by the Spanish court will list the individual beneficiaries or, if that is not possible, conditions that need to be fulfilled for a party to benefit from a judgment.


title: Class action

text: Swiss law does not allow for any form of class action. When the government proposed a new federal code of civil procedure in 2006, replacing the cantonal codes of civil procedure, it rejected the introduction of class actions, arguing that


title: Class action

text: The Civil Procedure Rules of the courts of England and Wales came into force in 1999 and have provided for representative actions in limited circumstances (under Part 19.6). These have not been much used, with only two reported cases at the court of first instance in the first ten years after the Civil Procedure Rules took effect. However, a sectoral mechanism was adopted by the Consumer Rights Act 2015, taking effect on October 1, 2015. Under the provisions therein, opt-in or opt-out collective procedures may be certified for breaches of competition law. This is currently the closest mechanism to a class action in England and Wales.


title: Class action

text: In the United States, the class representative, also called a lead plaintiff, named plaintiff, or representative plaintiff is the named party in a class-action lawsuit. Although the class representative is named as a party to the litigation, the court must approve the class representative when it certifies the lawsuit as a class action.


title: Class action

text: The class representative must be able to represent the interests of all the members of the class, by being typical of the class members and not having conflicts with them. He or she is responsible for hiring the attorney, filing the lawsuit, consulting on the case, and agreeing to any settlement. In exchange, the class representative may be entitled to compensation (at the court's discretion) out of the recovery amount.


title: Class action

text: In federal courts, class actions are governed by Federal Rules of Civil Procedure Rule and 28 U.S.C.A. § 1332(d). Cases in federal courts are only allowed to proceed as class actions if the court has jurisdiction to hear the case, and if the case meets the criteria set out in Rule 23. In the vast majority of federal class actions, the class is acting as the plaintiff. However, Rule 23 also provides for defendant class actions.


title: Class action

text: Typically, federal courts are thought to be more favorable for defendants, and state courts more favorable for plaintiffs. Many class actions are filed initially in state court. The defendant will frequently try to remove the case to federal court. The Class Action Fairness Act of 2005 increases defendants' ability to remove state cases to federal court by giving federal courts original jurisdiction for all class actions with damages exceeding $5,000,000 exclusive of interest and costs. The Class Action Fairness Act contains carve-outs for, among other things, shareholder class actions covered by the Private Securities Litigation Reform Act of 1995 and those concerning internal corporate governance issues (the latter typically being brought as shareholder derivative actions in the state courts of Delaware, the state of incorporation of most large corporations).


title: Class action

text: In securities class actions that allege violations of Section 11 of the Securities Act of 1933, "officers and directors are liable together with the corporation for material misrepresentations in the registration statement." To have "standing" to sue under Section 11 of the 1933 Act in a class action, a plaintiff must be able to prove that he can "trace" his shares to the registration statement and offering in question, as to which there is alleged a material misstatement or omission. In the absence of an ability to actually trace his shares, such as when securities issued at multiple times are held by the Depository Trust Company in a fungible bulk and physical tracing of particular shares may be impossible, the plaintiff may be barred from pursuing his claim for lack of standing.


title: Class action

text: Class actions may be brought in federal court if the claim arises under federal law or if the claim falls under 28 U.S.C. § 1332(d). Under § 1332(d)(2) the federal district courts have original jurisdiction over any civil action where the amount in controversy exceeds $5,000,000 and


title: Class action

text: Nationwide plaintiff classes are possible, but such suits must have a commonality of issues across state lines. This may be difficult if the civil law in the various states lack significant commonalities. Large class actions brought in federal court frequently are consolidated for pre-trial purposes through the device of multidistrict litigation (MDL). It is also possible to bring class actions under state law, and in some cases the court may extend its jurisdiction to all the members of the class, including out of state (or even internationally) as the key element is the jurisdiction that the court has over the defendant.


title: Class action

text: For the case to proceed as a class action and bind absent class members, the court must certify the class under Rule 23 on a motion from the party wishing to proceed on a class basis. For a class to be certified, the moving party must meet all of the criteria listed under Rule 23(a), and at least one of the criteria listed under Rule 23(b).


title: Class action

text: The 23(a) criteria are referred to as numerosity, commonality, typicality, and adequacy. Numerosity refers to the number of people in the class. To be certified, the class has to have enough members that simply adding each of them as a named party to the lawsuit would be impractical. There is no bright-line rule to determine numerosity, but classes with hundreds of members are generally deemed to be sufficiently numerous. To satisfy commonality, there must be a common question of law and fact such that "determination of its truth or falsity will resolve an issue that is central to the validity of each one of the claims in one stroke". The typicality requirement ensures that the claims or defenses of the named plaintiff are typical of those of everyone else in the class. Finally, adequacy requirement states that the named plaintiff must fairly and adequately represent the interests of the absent class members.


title: Class action

text: Rule 23(b)(3) allows class certification if "questions of law or fact common to class members "predominate" over any questions affecting only individual members, and that a class action is "superior" to other available methods for fairly and efficiently adjudicating the controversy."


title: Class action

text: Due process requires in most cases that notice describing the class action be sent, published, or broadcast to class members. As part of this notice procedure, there may have to be several notices, first a notice allowing class members to opt out of the class, i.e. if individuals wish to proceed with their own litigation they are entitled to do so, only to the extent that they give timely notice to the class counsel or the court that they are opting out. Second, if there is a settlement proposal, the court will usually direct the class counsel to send a settlement notice to all the members of the certified class, informing them of the details of the proposed settlement.


title: Class action

text: Since 1938, many states have adopted rules similar to the FRCP. However, some states, like California, have civil procedure systems, which deviate significantly from the federal rules; the California Codes provide for four separate types of class actions. As a result, there are two separate treatises devoted solely to the complex topic of California class actions. Some states, such as Virginia, do not provide for any class actions, while others, such as New York, limit the types of claims that may be brought as class actions.


title: Sexting

text: Sexting is sending, receiving, or forwarding sexually explicit messages, photographs, or videos, primarily between mobile phones. It may also include the use of a computer or any digital device. The term was first popularized early in the 21st century and is a portmanteau of "sex" and "texting", where the latter is meant in the wide sense of sending a text possibly with images. Sexting is not an isolated phenomenon but one of many different types of sexual interaction in digital contexts that is related to sexual arousal.


title: Sexting

text: The first published use of the term "sexting" was in a 2005 article in the Australian "Sunday Telegraph Magazine". In August 2012, the word "sexting" was listed for the first time in Merriam-Webster's "Collegiate Dictionary".


title: Sexting

text: The Pew Research Center commissioned a study on sexting, which divides the practice into three types:


title: Sexting

text: Sexting has become more common with the rise in camera phones and smartphones with Internet access, that can be used to send explicit photographs as well as messages. While sexting is done by people of all ages, most media coverage fixates on negative aspects of adolescent usage. Young adults use the medium of the text message much more than any other new media to transmit messages of a sexual nature, and teenagers who have unlimited text messaging plans are more likely to receive sexually explicit texts.


title: Sexting

text: As a result of sexting being a relatively recent practice, ethics are still being established by both those who engage in it and those who create legislation based on this concept. Whether sexting is seen as a positive or negative experience typically rests on the basis of whether or not consent was given to share the images. Nevertheless, Australian laws currently view under-18s as being unable to give consent to sexting, even if they meet the legal age for sexual consent.


title: Sexting

text: Contrary to common misconception, when it comes to preventing abuse among adolescents, consent is more important than trying to stop sexting altogether.


title: Sexting

text: Sexting has been promoted further by several direct messaging applications that are available on smartphones. The difference between using these applications and traditional texting is that content is transmitted over the Internet or a data plan, allowing anyone with Internet access to participate. Snapchat appeals to teens because it allows users to send photos for a maximum of ten seconds before they self-destruct. Those sending photos over Snapchat believe they will disappear without consequences so they feel more secure about sending them. There have been several cases where teens have sent photos over these applications, expecting them to disappear or be seen by the recipient only, yet are saved and distributed, carrying social and legal implications. Even though users believe their photos on Snapchat for example will go away in seconds, it is easy to save them through other photo capturing technology, third party applications, or simple screenshots. These applications claim no responsibility for explicit messages or photos that are saved. Snapchat's privacy policy on sexting has evolved to include sending content over new smartphone applications because of their appealing features such as the anonymity or temporary elements. These applications carry the same risks and consequences that have always existed.


title: Sexting

text: A 2009 study found that 4 percent of teenagers aged 14 to 17 claim to have sent sexually explicit photos of themselves. Fifteen percent of these teens also claimed to have received sexually explicit photos. This suggests a consent issue of people receiving photos without asking for them. This is enhanced with Snapchat, as the person receiving snapchats will not be aware of the contents until they open it, and messages are automatically deleted after some time. Although sexting through Snapchat is popular, "joke sexting" is more prevalent among users. Sending sexual images as a joke makes up approximately a quarter of the participants.


title: Sexting

text: Sexting is a prevalent and normalized practice among youth in many western, liberal democracies. Many couples engage in sexting. In a 2011 study, 54% of the sample had sent explicit pictures or videos to their partners at least once, and one third of their sample had engaged in such activities occasionally.


title: Sexting

text: In areas where gender roles traditionally expect men to initiate sexual encounters, sexting is used by women to offer nude images to male partners, allowing women greater latitude to instigate sex.


title: Sexting

text: Mass media does not encourage teen or underage sexting, because of the child pornography laws they could violate. However, a recent study found young women are significantly more likely than young men to be pressured into sending a nude photo, by their partner.


title: Sexting

text: In 2013, it was found that sexting is often used to enhance the relationship and sexual satisfaction in a romantic partnership. Sexting thus can be considered a "behaviour that ties into sexuality and the subsequent level of relationship satisfaction experienced by both partners". Based on the interviews conducted by Albury and Crawford, they discovered that sexting is commonly used in positive aspects. According to Albury and Crawford, sexting was not only an activity occurring in the context of flirtation or sexual relationships, but also between friends, as a joke or during a moment of bonding." Reportedly, hedonism played a role in motivating sexting, and the length of relationship was negatively correlated with sexting behaviors. The study had a small sample size, so more research needs to be done surrounding sexting and motivation, but it is clear that sexting is a phenomenon that is not constrained to simply unattached individuals looking for fun; it is used by those in intimate relationships to increase feelings of intimacy and closeness one's partner. For teens, sexting can also act as a prelude (or in lieu of) sexual activity, as an experimental phase for those who are yet to be sexually active, and for those who are hoping to start a relationship with someone. In a 2013 study conducted by Drouin et al., it was found that sexting is also associated with attachment styles, as those with attachment avoidance are more likely to engage in sexting behaviours (just as these individuals are also more likely to engage in casual sex). Thus, instead of increasing intimacy in these types of relationships, sexting may act as a buffer for physical intimacy.


title: Sexting

text: While some studies have evaluated sexting by married couples or young men who have sex with men, the majority of attention is directed at heterosexual adolescents.


title: Sexting

text: A 2015 online survey of a population representative quota sample of N=1,500 adults in Germany (ages 18 to 85; 48% women, 52% men) showed that 41% of the respondents had sent a sext at least once in their lives. Sending erotic texts was most common, followed by erotic photos and videos of oneself. A statistically significant increase in participation in sexting was shown by persons of male gender, younger age, marital status unmarried and non-heterosexual identity. The respondents reported significantly more positive than negative effects of their sexting activities.


title: Sexting

text: Some studies of adolescents find that sexting is correlated with risky sex behaviors, while other studies have found no link. Although the focus has been primarily on heterosexual teenagers, a recent study demonstrates that the number of people that send sexual images of themselves vary.


title: Sexting

text: In a 2008 survey of 1,280 teenagers and young adults of both sexes sponsored by "The National Campaign to Prevent Teen and Unplanned Pregnancy", 20% of teens (13–20) and 33% of young adults (20–26) had sent nude or semi-nude photographs of themselves electronically. Additionally, 39% of teens and 59% of young adults had sent sexually explicit text messages.


title: Sexting

text: Sexting became popular among teens around 2009, especially among high school students in the United States, where 20 percent of high school students said they had engaged in sexting or receiving.


title: Sexting

text: A widely cited 2011 study indicated the previously reported prevalence was exaggerated. Researchers at the University of New Hampshire surveyed 1,560 children and caregivers, reporting that only 2.5 percent of respondents had sent, received or created sexual pictures distributed via cell phone in the previous year. Perhaps shedding light on the over-reporting of earlier studies, the researchers found that the figure rose to 9.6% when the definition was broadened from images prosecutable as child pornography to any suggestive image, not necessarily nude ones.


title: Sexting

text: Despite this, a 2012 study conducted by the University of Utah Department of Psychology has received wide international media attention for calling into question the findings reported by the University of New Hampshire researchers. In the University of Utah's study, researchers Donald S. Strassberg, Ryan Kelly McKinnon, Michael A. Sustaíta, and Jordan Rullo surveyed 606 teenagers ages 14 to 18 and found that nearly 20 percent of the students said they had sent a sexually explicit image of themselves via cell phone, and nearly twice as many said that they had received a sexually explicit picture. Of those receiving such a picture, over 25 percent indicated that they had forwarded it to others. In addition, of those who had sent a sexually explicit picture, over a third had done so despite believing that there could be serious legal and other consequences if they got caught. Students who had sent a picture by cell phone were more likely than others to find the activity acceptable. Strassberg, McKinnon, "et al". note: "The news-worthiness of [the University of New Hampshire study] derives from [their] figure [2.5%] being far below (by a factor of 5 or more) the prevalence rates reported in the previous surveys. However, while technically accurate, the 2.5% figure is actually rather misleading. As seen in Table 1 of their publication, Mitchell et al. found that among the quarter of their sample that were ages 10 to 12, [less than] 0.6% 'appeared in, created, or received a nude or nearly nude image' while among those age 15 to 17, 15% of participants reported having done so. Despite it being widely reported in the media, the overall prevalence figure of 2.5% masks a dramatic age effect that indicates that more than 1 in 8 mid-teen minors admit to having sexted." Strassberg, McKinnon, et al. conclude: "These results argue for educational efforts such as cell phone safety assemblies, awareness days, integration into class curriculum and teacher training, designed to raise awareness about the potential consequences of sexting among young people."


title: Sexting

text: According to a writing by professor Diane Kholos Wysocki, although both men and women participate in "sexting", "women are more likely to sext than men". Even though the article claims that women are more likely to sext than men, the article does not claim that women are the only ones receiving the images. In a study, close to half of the adults' interviewed had sexual photos or texts on their mobile device(s). Many of these intimate images and words are actually sent to complete strangers. In an article in "Scientific American", however, the article says that men are actually more likely to initiate some form of intimate communication, like sending nude photographs or suggestive text messages. The reasoning behind this is that men seem to be more open about their sexual drive, which promotes the instigation of sexual contact. Also in this article, it says, "The age group that is most keen on sexting is 18- to 24-year-olds". This is when young adults are at their prime of sexuality, and are looking to find their partners while also exploring their bodies and sexuality. Amy Adele Hasinoff published an article trying to get rid of the stigma that sexting is simply exploitation of sexual matters. Women are sexualized whenever they post or share any form of intimate media. Men are not. When it comes to sexting, there is a big difference between sexual exploitation and a consensual decision to express one's sexuality and share an image of their own body with someone who wants to see it. Hasinoff points out that "Many digital media scholars stress that the Internet can enable young people to explore their identities and develop social and communication skills" (Boyd, 2008; Tynes, 2007), and suggests that consensual sexting might serve a similar function for some people.


title: Sexting

text: The body of academic literature on sexting has been growing rapidly since the early 2000s. Several research reviews are available that summarize the current state of research. Such research reviews often focus on the prevalence of sexting in different populations, on the age and gender of sexters, on motivations for sexting, and on positive and negative sexting outcomes. Importantly, more and more primary studies and research reviews clearly differentiate between "consensual sexting" on the one side and "non-consensual sexting" including different types of technology-mediated violence such as sextortion and so-called "revenge porn". There are also research reviews available that summarize and evaluate extant measures to prevent negative sexting outcomes and nonconsensual sexting.


title: Sexting

text: If a person sends an explicit image of themselves to a partner, then it can be against the law to re-transmit a copy of that image to another person without the consent of the originator. Some countries have revenge porn laws that prevent the publication of sexual images without consent of parties in the image. While there are many possible legal avenues for prosecution of people who knowingly breach the confidence of those sending sexual messages, in practice, nude images can be widely propagated without the consent of the originator.


title: Sexting

text: Some young people blackmail their sexual partners and former partners by threatening to release private images of them. In a study conducted by Drouin et al. analyzing sexting behaviours among young adults, it was found that men would show the sexually explicit photos of their girlfriends to their friends. This is a new risk associated with new media, as prior to cell phones and email, it would be difficult to quickly distribute photos to acquaintances; with sexting, one can forward a photo in a matter of seconds.


title: Sexting

text: Studies have shown that sex crimes using digital media against minors reflect the same kind of victimization that happens offline. Family members, acquaintances and intimate partners make up the mass majority of perpetrators for digital media sex crimes. Research by the Internet Watch Foundation in 2012, estimated that 88% of self-made explicit images are "stolen" from their original upload location (typically social networks) and made available on other websites, in particular porn sites collecting sexual images of children and young people. The report highlighted the risk of severe depression for "sexters" who lose control of their images and videos.


title: Sexting

text: Sexting is seen as irresponsible and promiscuous for adolescents, but "fun and flirty" for adults. These risks tend to be exaggerated by news media, especially in regards to adolescent girls.


title: Sexting

text: The University of Utah study (with a population sample of 606 teens aged 14 to 18) stated that about one third of respondents did not consider legal or other consequences when receiving or sending sexts. Teenagers may not be thinking about the risks and repercussions when they participate in sexting; however, a study by Kath Albury titled "Selfies, Sexts, and Sneaky Hats: Young People's Understandings of Gendered Practices of Self-Presentation" shows that teenagers engaging in sexting were concerned that their parents may see or find out about their involvement with sexting. Some teenagers shared that their "main risks of parental discovery were embarrassment (for both parents and young people) and 'overreaction' from adults who feared the photo had been shared." While teenagers felt less compelled to worry about the legal risks with sexting, they worried that their parents would find out about their involvement with sexting. Albury and Crawford (2012) argue that adolescents are well aware of the differences between consensual sexting and distribution of private images with negative intent. Further, they argue young people are developing norms and ethics of sexting based on consent.


title: Sexting

text: Creation and distribution of explicit photos of teenagers violates child pornography laws in many jurisdictions (depending on the age of the people depicted), but this legal restriction does not align with the social norms of the population engaging in the practice, which distinguish between consensual activity and harassment or revenge. Senders in some jurisdictions may also be charged with distribution of indecent material to a minor, and could be required to register as a sex offender for life. Child pornography cases involving teen-to-teen sexting have been prosecuted in Oregon, Virginia, Nova Scotia and Maryland.


title: Sexting

text: While mainstream media outlets, parents, and educators are rightfully worried about the negative legal, social, and emotional ramifications of teen sexting, much less is said about the issue of sexual consent. According to a 2012 study conducted by professors at the University of New South Wales, due to child pornography laws that prohibit any minor from consenting to sexual activity, issues of consent among adolescent teens is seldom discussed. Much like the discourse surrounding "abstinence-only" education, the prevailing attitude towards sexting is how to prevent it from occurring rather than accepting its inevitability and channeling it in healthier ways. According to the study, instead of criminalizing teens who participate in sexting, the law should account for whether the images are shared consensually. This would mean adopting an "ethics" approach, one that teaches and guides teens on how to respect bodily autonomy and privacy.


title: Sexting

text: According to a study done by the health journal "Pediatrics", more than one in five middle school minors with behavioral or emotional problems has recently engaged in sexting. Those individuals who have reported sexting in the past six months were four to seven times more likely to engage in other sexual activities such as intimate kissing, touching genitals, and having vaginal or oral sex, compared to minors who stated they did not partake in sexting. The study included 420 participants who were between the ages of 12 and 14 years old. The children were pulled from five urban public middle schools in Rhode Island between 2009 and 2012. Seventeen percent of the children tested claimed they had sent a sexually explicit text message in the past six months. Another five percent admitted to sending sexually explicit text messages and nude or semi-nude photos.


title: Sexting

text: Sexting is generally legal if all parties are over the age of majority and images are sent with their consent and knowledge; however, any type of sexual message that both parties have not consented to can constitute sexual harassment.


title: Sexting

text: Sexting that involves minors under the age of consent sending an explicit photograph of themselves to a romantic partner of the same age can be illegal in countries where antichild pornography laws require all participants in pornographic media to be over the age of majority. Some teenagers who have texted photographs of themselves, or of their friends or partners, have been charged with distribution of child pornography, while those who have received the images have been charged with possession of child pornography; in some cases, the possession charge has been applied to school administrators who have investigated sexting incidents as well. The images involved in sexting are usually different in both nature and motivation from the type of content that anti-child pornography laws were created to address.


title: Sexting

text: A 2009 UK survey of 2,094 teens aged 11 to 18 found that 38% had received an "offensive or distressing" sexual image by text or email.


title: Sexting

text: In the United States, anyone who is involved in the electronic distribution of sexual photos of minors can face state and federal charges of child pornography. The laws disregard the consent of parties involved: "...regardless of one's age or consent to sexting, it is unlawful to produce, possess, or distribute explicit sexual images of anyone under 18." The University of New Hampshire's Crimes Against Children Research Center estimates that 7 percent of people arrested on suspicion of child pornography production in 2009 were teenagers who shared images with peers consensually.


title: Sexting

text: Kath Albury discusses in an article titled "Sexting, Consent, and Young People's Ethics: Beyond Megan's Story" that if teens are convicted of a sexting charge, they have to register as a sex offender, and this takes away the impact of the title of sex offender. A girl who agreed to send her girlfriend a naked picture is not as dangerous to the community as a child molester but the charge of sex offender would be applied equally to both of these cases.


title: Sexting

text: In a 2013 interview, assistant professor of communications at the University of Colorado Denver, Amy Adele Hasinoff, who studies the repercussions of sexting has stated that the "very harsh" child pornography laws are "designed to address adults exploiting children" and should not replace better sex education and consent training for teens. She went on to say, "Sexting is a sex act, and if it's consensual, that's fine..." "Anyone who distributes these pictures without consent is doing something malicious and abusive, but child pornography laws are too harsh to address it."


title: Sexting

text: According to Amy Hasinoff, if sexting was viewed as media production and a consensual activity, this would change the legal assumption that sexting is always non-consensual and reduce the culpability of victimized youth. This turns sexting into a situation that would lead to different legal consequences when distribution of the material was not consented to by the creator. Alvin J. Primack, who draws from Amy Hasinoff's work, argued a media production model may be useful for distinguishing between child pornography and sexting from a First Amendment perspective. According to Alvin J. Primack, the motivation for creating and distributing sexts (e.g., pleasure, relationship building) differs from the motivation for creating and distributing child pornography (e.g., abuse, exploitation), and the market of circulation is generally different between the two as well. For these reasons, there may be arguments – grounded in reasoning provided by First Amendment doctrine – for finding some youth sexts exchanged between persons who are of the age of consent to be legally-protected speech.


title: Sexting

text: Legal professionals and academics have expressed that the use of "child porn laws" with regard to sexting is "extreme" or "too harsh". Florida cyber crimes defense attorney David S. Seltzer wrote of this that "I do not believe that our child pornography laws were designed for these situations ... A conviction for possession of child pornography in Florida draws up to five years in prison for each picture or video, plus a lifelong requirement to register as a sex offender."


title: Sexting

text: Academics have argued that "sexting" is a broad term for images being sent over Internet and cell phones, between minors, adults, or minors and adults, and in an abusive manner or in an innocent manner. In order to develop policy better suited for adolescent sexting cases, it is necessary to have better terms and categories of sexting. University of New Hampshire typology has suggested the term "youth-produced sexual image" to classify adolescent sexting. Furthermore, they branch into two sub-categories: "aggravated" and "experimental youth-produced sexual image". Aggravated cases include cases of sexual assault, coercion, cyber-bullying, forwarding images without consent, and abusive behavior. Experimental cases are cases in which an adolescent willingly takes a picture and sends it to someone with no criminal intent and is attention-seeking. This terminology could lead to more appropriate action towards adolescents who engage in sexting.


title: Sexting

text: In Connecticut, Rep. Rosa Rebimbas introduced a bill that would lessen the penalty for "sexting" between two consenting minors in 2009.


title: Sexting

text: The bill would make it a Class A misdemeanor for children under 18 to send or receive text messages with other minors that include nude or sexual images. It is currently a felony for children to send such messages, and violators could end up on the state's sex offender registry.


title: Sexting

text: Vermont lawmakers introduced a bill in April 2009 to legalize the consensual exchange of graphic images between two people 13 to 18 years old. Passing along such images to others would remain a crime.


title: Sexting

text: In Ohio, a county prosecutor and two lawmakers proposed a law that would reduce sexting from a felony to a first degree misdemeanor, and eliminate the possibility of a teenage offender being labeled a sex offender for years. The proposal was supported by the parents of Jesse Logan, a Cincinnati 18-year-old who committed suicide after the naked picture of herself which she sexted was forwarded to people in her high school.


title: Sexting

text: Utah lawmakers lessened the penalty for sexting for someone younger than 18 to a misdemeanor from a felony.


title: Sexting

text: In New York, Assemblyman Ken Zebrowski (D-Rockland) has introduced a bill that will create an affirmative defense where a minor is charged under child pornography laws if they possesses or disseminate a picture of themselves or possess or disseminates the image of another minor (within 4 years of their age) with their consent. The affirmative defense will not be available if the conduct was done without consent. It also creates an educational outreach program for teens that promotes awareness about the dangers of sexting.


title: Sexting

text: In the Australian state of Victoria, the law was reformed in 2014 to create a defence for young people who engage in consensual sexting and the introduction of the new offences of distribution of an intimate image, and threat to distribute an intimate image.


title: In the Land of Leadale

text: A manga adaptation with art by Dashio Tsukimi and composition by Ryō Suzukaze has been serialized online via ASCII Media Works' "Dengeki PlayStation Comic Web" website since July 2019 and has been collected in three "tankōbon" volumes. Both the light novel and manga are licensed in North America by Yen Press. An anime television series adaptation by Maho Film aired from January to March 2022.


title: In the Land of Leadale

text: In Japan, a VR-accessed multi-player online fantasy role-playing game (VRMMORPG) named "Leadale", which offers a very liberal customization system, has become immensely popular in recent years. A young girl named Keina Kagami, rendered permanently paralzyed and on constant life support, uses this game from her hospital bed to interact with the rest of the world. When she unexpectedly dies after her life support shuts down during a power outage, she finds herself reborn into the game world of Leadale, in the body of her personal avatar Cayna. To her surprise, she also finds out that 200 years have passed in Leadale since she last logged into the game, a period in which the seven nations she knew were devastated by war and re-organized into three new kingdoms.


title: In the Land of Leadale

text: As Cayna begins making her way in this new world and meeting the three NPC children she had adopted in the game, she finds out that her death ruined "Leadale's" reputation, causing the game's shutdown. However, several other players ended up trapped inside the game as well, some of them for years, and the kingdoms of Felskeilo, Helshper and Otaloquess are increasingly plagued by attacks from high-level monsters, all stemming from "Leadale's" abrupt cancellation, which made them go rogue inside this world. What's more, some powerful character seems to have set his sights on Cayna herself as his future bride. And it is only after she meets her former mentor to the game, Opus, in the game again that she learns that "Leadale" was specifically created to help her out of her isolation following her accident, but was commercialized afterwards. The game had, however, the unfortunate side effect of displacing the minds of several players into the virtual Leadale world. After Keina's death, Opus synchronized the game system with her new elven soul, essentially making it into a real living world.


title: In the Land of Leadale

text: "In the Land of Leadale" is written by Ceez and illustrated by Tenmaso. Originally serialized online on the Shōsetsuka ni Narō website between November 2010 and December 2012, Enterbrain began publishing the series in print in January 2019 under their Famitsu Bunko imprint. Eight volumes have been released so far. Yen Press licensed the series in North America.


title: In the Land of Leadale

text: A manga adaptation illustrated by Dashio Tsukimi and composed by Ryō Suzukaze began serialization online via ASCII Media Works' "Dengeki PlayStation Comic Web" website in July 2019. Four "tankōbon" volumes have been released so far. Yen Press has also licensed the manga and will release the first volume in March 2022.


title: In the Land of Leadale

text: On February 22, 2021, an anime adaptation was announced. At "Kadokawa Light Novel Expo 2020", it was revealed to be a television series animated by Maho Film. The series is directed by Takeyuki Yanase, with scripts overseen by Kazuyuki Fudeyasu, character designs handled by Toshihide Matsudate, Eri Kojima, and Kaho Deguchi, and music composed by Kujira Yumemi. The series aired from January 5 to March 23, 2022, on Tokyo MX and other networks. The opening theme song is "Happy encount" by TRUE, while the ending theme song is "Hakoniwa no Kōfuku" (Happiness in a Miniature Garden) by Azusa Tadokoro. Crunchyroll licensed the series.


title: In the Land of Leadale

text: On January 13, 2022, Crunchyroll announced that the series will receive an English dub, which premiered on February 16.


title: Arithmetic mean

text: In mathematics and statistics, the arithmetic mean ( ) or arithmetic average, or just the "mean" or the "average" (when the context is clear), is the sum of a collection of numbers divided by the count of numbers in the collection. The collection is often a set of results of an experiment or an observational study, or frequently a set of results from a survey. The term "arithmetic mean" is preferred in some contexts in mathematics and statistics, because it helps distinguish it from other means, such as the geometric mean and the harmonic mean.


title: Arithmetic mean

text: In addition to mathematics and statistics, the arithmetic mean is used frequently in many diverse fields such as economics, anthropology and history, and it is used in almost every academic field to some extent. For example, per capita income is the arithmetic average income of a nation's population.


title: Arithmetic mean

text: While the arithmetic mean is often used to report central tendencies, it is not a robust statistic, meaning that it is greatly influenced by outliers (values that are very much larger or smaller than most of the values). For skewed distributions, such as the distribution of income for which a few people's incomes are substantially greater than most people's, the arithmetic mean may not coincide with one's notion of "middle", and robust statistics, such as the median, may provide better description of central tendency.


title: Arithmetic mean

text: Given a data set formula_1, the "arithmetic mean" (or "mean" or "average"), denoted formula_2 (read formula_3 "bar"), is the mean of the formula_4 values formula_5.


title: Arithmetic mean

text: The arithmetic mean is the most commonly used and readily understood measure of central tendency in a data set. In statistics, the term average refers to any of the measures of central tendency. The arithmetic mean of a set of observed data is defined as being equal to the sum of the numerical values of each and every observation, divided by the total number of observations. Symbolically, if we have a data set consisting of the values formula_6, then the arithmetic mean formula_7 is defined by the formula:


title: Arithmetic mean

text: For example, if the monthly salaries of 10 employees of a firm are: 2500, 2700, 2400, 2300, 2550, 2650, 2750, 2450, 2600, 2400, then the arithmetic mean is


title: Arithmetic mean

text: If the data set is a statistical population (i.e., consists of every possible observation and not just a subset of them), then the mean of that population is called the "population mean", and denoted by the Greek letter formula_10. If the data set is a statistical sample (a subset of the population), it is called the "sample mean" (which for a data set formula_11 is denoted as formula_12).


title: Arithmetic mean

text: The arithmetic mean can be similarly defined for vectors in multiple dimension, not only scalar values; this is often referred to as a centroid. More generally, because the arithmetic mean is a convex combination (coefficients sum to 1), it can be defined on a convex space, not only a vector space.


title: Arithmetic mean

text: The arithmetic mean has several properties that make it useful, especially as a measure of central tendency. These include:


title: Arithmetic mean

text: The arithmetic mean may be contrasted with the median. The median is defined such that no more than half the values are larger than, and no more than half are smaller than, the median. If elements in the data increase arithmetically, when placed in some order, then the median and arithmetic average are equal. For example, consider the data sample formula_21. The average is formula_22, as is the median. However, when we consider a sample that cannot be arranged so as to increase arithmetically, such as formula_23, the median and arithmetic average can differ significantly. In this case, the arithmetic average is 6.2, while the median is 4. In general, the average value can vary significantly from most values in the sample, and can be larger or smaller than most of them.


title: Arithmetic mean

text: There are applications of this phenomenon in many fields. For example, since the 1980s, the median income in the United States has increased more slowly than the arithmetic average of income.


title: Arithmetic mean

text: A weighted average, or weighted mean, is an average in which some data points count more heavily than others, in that they are given more weight in the calculation.<ref>


title: Kang Ki-young

text: Kang Ki-young (born October 14, 1983) is a South Korean actor. He is well-known for his supporting roles in a number of popular Korean dramas.


title: Bulgaria national football team

text: The Bulgaria national football team () represents Bulgaria in men's international football and is administered by the Bulgarian Football Union, a member association of UEFA.


title: Bulgaria national football team

text: Bulgaria's best achievements are reaching the final at the 1968 Summer Olympics and the fourth place at the FIFA World Cup in 1994. Bulgaria have competed at a total of seven World Cups, debuting in 1962 and last appearing in 1998. In addition, they have participated in two European Championships, in 1996 and 2004. The team has also competed at the Balkan Cup, winning three titles. However, Bulgaria have failed to qualify for any major tournament since UEFA Euro 2004.


title: Bulgaria national football team

text: The Bulgarian national football team was formed in 1922. In 1923, the Bulgarian Football Union was formed and the team's first match was held in Vienna on 21 May 1924, which resulted in a 6–0 defeat against Austria. Bulgaria also participated in the 1924 Summer Olympics in Paris a few days later.


title: Bulgaria national football team

text: After being unable to compete in the 1930 World Cup, the Bulgarian side did not qualify for any major tournament for nearly 30 years, narrowly falling short of qualification on numerous occasions. The national team had gone on a streak of finishing 2nd or 3rd in their qualifying groups along with proceeding to the play-offs, but in the end, failing to qualify. Despite their qualifying problems, the national team did manage to defeat many elite teams during memorable international friendlies during those years. It also seemed as if the only tournaments they managed to qualify for were smaller tournaments, such as the Balkan Cup, which they won three times (1931, 1932 and 1973–76), thus being the competition's second most successful team only behind Romania with four titles.


title: Bulgaria national football team

text: Bulgaria qualified for the World Cup for the first time in its history in 1962 and followed that up with consecutive appearances in 1966, 1970 and 1974. The team, however, did not have much success and finished in third place in their group two out of the four times.


title: Bulgaria national football team

text: Bulgaria took part in qualifiers for the European Championship in 1968 and went on to win their group with impressive wins over Norway, Sweden, and Portugal. Although they would go on to lose to the eventual champions and hosts Italy in a two-legged qualifying play-off.


title: Bulgaria national football team

text: At the 1968 Summer Olympics, the team won the silver medal. They finished first in Group D by defeating Thailand 7–0, Guatemala 2–1, and drawing 2–2 against Czechoslovakia. They advanced to the quarter-finals by defeating Israel and then the semi-finals by defeating favored hosts Mexico. In the Olympic Final, the team was defeated by Hungary, in what many would say was a hard-fought match for both sides.


title: Bulgaria national football team

text: Despite winning the Balkan Cup twice in 1931 and 1932, the Bulgaria national team added two more trophies to their case as they went on to win the tournament in 1973 and 1976. In both 1973 and 1976, Bulgaria had used their previous World Cup experience to create a very tactical team. This paid off quite well, as they had many decisive victories over Hungary, Greece, Turkey, Yugoslavia, Poland, Albania and Romania. In fact, the team won the 1976 Balkan Cup by beating Romania in the two-legged final 1–0 and 3–2.


title: Bulgaria national football team

text: Bulgaria finally qualified for their second world cup. Bulgaria was drawn in a tough group with elite opponents in England, powerhouse Argentina and Hungary. Bulgaria opened up their campaign with a narrow 0–1 loss to Argentina. Later on, Bulgaria would lose their second group match by a 6–1 score to Hungary. Bulgaria's hopes of qualifying were over, but the national team impressively drew with future 1966 World Cup champions England 0-0 and finished fourth in the group with only one point.


title: Bulgaria national football team

text: Bulgaria qualified for their second straight World Cup, drawn into an even tougher group compared to the previous World Cup. They were placed in the group of death with superpowers Hungary, Portugal and Brazil, with Pelé at the helm. Bulgaria opened their campaign match with a 0–2 loss to Brazil thanks to two free kick goals by Pelé and Garrincha. In their second match Bulgaria loss 0–3 to Eusebio's Portugal. Finally, Bulgaria with no chance of advancing to the next round, finished their last match with a 1–3 loss to Hungary. Bulgaria once again finished fourth with zero points in the group.


title: Bulgaria national football team

text: After their poor World Cup performance, Bulgaria was determined to redeem themselves. Bulgaria was drawn in a very tough group for qualifying, with Norway and Sweden, along with Eusebio's Portugal. Bulgaria started off with a 4–2 win over Norway. They would add to their winning streak with a 2–0 victory against Sweden. In their next two matches Bulgaria would draw 0–0 against Norway, and dominate Sweden 3–0. In their final two group fixtures Bulgaria played Portugal to a 1–0 victory at home and an 0–0 draw on the road, but it was enough to advance to the two-legged qualifying play-off. There Bulgaria were drawn against eventual Euro 1968 host Italy. Italy were defeated in the first leg 3–2, but won the second by a 0–2 score to advance 4–3 on aggregate. Italy would win the playoff and go on to win the tournament, while Bulgaria was eliminated from reaching the finals.


title: Bulgaria national football team

text: A month and a half after the European Championship qualifying came the Olympics, which Bulgaria had qualified for the fifth time in their history. They were drawn in a simple group with Thailand, Guatemala and Czechoslovakia. Bulgaria started off with a 7–0 thrashing of Thailand. They later went on and drew with Czechoslovakia 2–2 to increase their point standards. Their final match once again determined if they would carry on to the quarter-finals. Needing a decisive win, Bulgaria went on to defeat Guatemala 2–1 and win their Olympic group. They qualified directly to the quarter-finals facing underdogs, Israel. The game remained 1–1 for most of the match until a drawing of lots determined who would go on to the semi-finals of the tournament. Winning the draw Bulgaria advanced to the semi-finals against Mexico. After a very hard-fought match, Bulgaria proved stronger as they came out on top with a 3–2 victory. Bulgaria advanced to the finals for the first time in their Olympic history. They were determined to win the gold medal, but fell short with a 1–4 loss to Hungary. Although battling hard, Bulgaria came out with the silver medal.


title: Bulgaria national football team

text: Bulgaria qualified for their third straight World Cup, held in Mexico, just like the 1968 Olympics. They were drawn in a very tricky group with Germany, Peru and Morocco. Bulgaria played their first match against Peru, losing 3–2. Germany won Bulgaria's second match, 5–2. The last group stage match ended 1–1; Bulgaria ended up in 3rd place.


title: Bulgaria national football team

text: The 1974 World Cup was held in West Germany. They were drawn in a decently tough group, with the Netherlands, Sweden and Uruguay. Bulgaria started off with a goalless draw with Sweden. They drew again, this time 1–1 with Uruguay. As the final match came, Bulgaria fell by a 4–1 score. Bulgaria remained in third place in the group stages.


title: Bulgaria national football team

text: Bulgaria qualified for the 1986 World Cup in Mexico by finishing second in Group Four, behind France with 11 points, but ahead of powerful rivals Yugoslavia and East Germany. This was their fifth World Cup appearance. They were drawn in Group A with Italy, Argentina, and South Korea. In the opening match of the World Cup, the Bulgarians held the defending champions Italy to an impressive 1–1 draw. Alessandro Altobelli gave the Italians the lead, but an 85th-minute equalizer by Nasko Sirakov gave the Bulgarians the point they needed. The next match was another 1–1 draw against South Korea with the goal for Bulgaria coming from Plamen Getov in the 11th minute. They lost the final match of the group 2–0 against Argentina, who eventually won the tournament. Despite not recording a win, the Bulgarians advanced to the knockout stage by being the third-best third-placed team. By doing so, Bulgaria along with Uruguay became the first nations to qualify for the knockout stage without winning a game in the first round. In the Round of 16, they faced World Cup hosts Mexico, who were looking for revenge due to their previous home Olympic semi-final loss to Bulgaria in Mexico City in 1968. The match was hard-fought from both sides of the scale but ultimately, Mexico came away with the 2–0 win.


title: Bulgaria national football team

text: Certainly one of the most important dates in Bulgarian football history is 17 November 1993, a date on which Emil Kostadinov scored a deciding goal in the 90th minute to beat France in Paris, allowing Bulgaria to qualify for the World Cup in the United States in 1994. Under the management of Dimitar Penev, the Bulgarians, led by players such as Hristo Stoichkov, Yordan Lechkov, and Krasimir Balakov, along with a multitude of other talented players remembered in Bulgaria as the "Golden Generation", made a strong impression by surprisingly reaching the semi-finals. They entered a very tough Group D with 1990 World Cup runners-up Argentina with Diego Maradona at the helm, African Nations Cup champions Nigeria, and Balkan rivals Greece. The first match ended with a 3–0 defeat to Nigeria. Despite the bad start, the team made quite a huge statement by winning 4–0 against their Greece and increasing their goal difference. Their third and final match came against Argentina. The powerful Bulgarian side came away with a shocking 2–0 victory. Going into injury-time, Argentina was leading the group. A 91st-minute strike from Nasko Sirakov, however, meant that they'd drop two places and finish third.


title: Bulgaria national football team

text: Bulgaria continued to the round of 16, where they faced Mexico. Stoichkov opened the scoring in the sixth minute with an incredible strike off a break away from outside the box, tallying his fourth goal. The match ended 1–1 and after no goals were scored in extra time, penalties decided which team would go through. Team captain Borislav Mihaylov saved the first three penalty kicks in a row, breaking the World Cup record. Bulgaria won 3–1 on penalties. In the quarter-finals, Bulgaria faced the defending world champions Germany. At the start of the match held in Giants Stadium in East Rutherford, New Jersey, the Bulgarians dominated impressively, hitting the post twice in the process, but eventually found themselves behind after Lothar Matthäus scored the opening goal for the Germans. The Bulgarians, however, managed to turn the game over with a swerving free kick by Hristo Stoichkov and a flying header by Yordan Lechkov, giving them a 2–1 win. In the semi-finals, they controversially lost 2–1 to Italy. Stoichkov scored Bulgaria's only goal in the first half to tally his seventh goal, which led the tournament. In the second half, Bulgaria were waved off on a non-penalty call in which an Italian defender had clearly committed a handball in the box, off a Kostadinov cross. Instead of playing in the final, it became a third place play-off. Bulgaria lost against Sweden 4–0, but the fourth-place finish was Bulgaria's best performance in history to that point.


title: Bulgaria national football team

text: Hristo Stoichkov was awarded the Golden Boot shared with Oleg Salenko as the top scorer in the tournament with his six goals. Krasimir Balakov was named in the 1994 World Cup Dream Team along with Stoichkov. Later on in December, Stoichkov was awarded the FIFA Ballon D'Or trophy for his great skill and leadership, becoming the first Bulgarian and third Barcelona player to win it in history.


title: Bulgaria national football team

text: In 1996, the team qualified for the European Football Championship for the first time. They were drawn in Group B with France, Spain, and Romania. Bulgaria started with a 1–1 draw against the Spain. Stoichkov scored his second goal with a wonderful volley, ruled offside. Bulgaria defeated Romania 1–0 in the next group stage match. Stoichkov scored in the third minute. In the final group match, the Bulgarian side lost 3–1 against France; Stoichkov scored a free kick to give Bulgaria their only goal of the game, along with their only loss. At the same time, Spain defeated Romania 2–1, and Bulgaria were eliminated.


title: Bulgaria national football team

text: Bulgaria qualified for the 1998 World Cup in France by finishing first in Group 5, with decisive wins over Russia. They entered the competition with new manager Hristo Bonev. Bulgaria drew Spain, Nigeria, and Paraguay in Group D. The first match ended decently, in a goalless draw against eventual group runners up Paraguay. In the second match, the Bulgarians lost 1–0 for a second-straight World Cup to Nigeria. The final match ended with a 6–1 defeat to Spain. Following the bad results, Bulgaria finished fourth in the group, with only one point. This was the last World Cup appearance for Bulgaria.


title: Bulgaria national football team

text: Bulgaria was drawn in a tough qualifying group with teams England, Sweden, and Poland. The campaign started slow with a draw and a defeat by Poland and Sweden. The most memorable match for Bulgaria in the group was the 1–1 draw against England, which was also the last match for Stoichkov before his international retirement. Bulgaria finished fourth with eight points and failed to make the final stages of Euro 2000.


title: Bulgaria national football team

text: Bulgaria was once again drawn into a tough group with Denmark and Czech Republic. The group was also the debut of Bulgaria's top scoring legend Dimitar Berbatov. Bulgaria won the matches against the weaker teams, but lost once and drew once with both Denmark and the Czech Republic. Bulgaria finished third with 17 points, three points behind second-placed Czech Republic, thus failing to make the World Cup in South Korea and Japan.


title: Bulgaria national football team

text: Bulgaria managed to qualify for the Euro 2004 in Portugal by finishing first with wins over Croatia and Belgium. They drew Sweden, Italy, and Denmark in Group C. All three group stage matches ended up in losses for Bulgaria, with Martin Petrov being the team's lone scorer in the country's 1–2 loss to Italy.


title: Bulgaria national football team

text: Bulgaria failed to qualify for the World Cup in Germany after a run of poor results. They tied with Sweden and Croatia the first run but lost the other meetings to the two sides. Although Berbatov scored many goals in the qualifiers including a last-minute equalizer against Croatia, Bulgaria still finished third in qualifying with 15 points.


title: Bulgaria national football team

text: Bulgaria found themselves in a minor tournament in Japan known as the Kirin Cup. They started off well with a 2–1 victory over the hosts Japan. However, Bulgaria lost 5–1 to Scotland, the eventual cup champions. Bulgaria finished as the runners-up and received the silver medal.


title: Bulgaria national football team

text: Group G of Euro 2008 qualification had Netherlands, Romania, and Bulgaria attempting to qualify for Euro 2008, hosted by Switzerland and Austria. Bulgaria performed well after a run of good results against Romania which gave them the first place. Bulgaria finished third in the group falling short on one point behind the Netherlands.


title: Bulgaria national football team

text: Bulgaria were drawn against Italy and Ireland in qualifying in Group 8. Bulgaria started the campaign with a series of draws. Manager Plamen Markov was replaced by Stanimir Stoilov in January 2009. The Bulgarians then recorded their first wins of the group over Cyprus, Montenegro and Georgia. They finished in third place with 14 points, therefore failing to qualify to a play-off spot.


title: Bulgaria national football team

text: Bulgaria were drawn in Group G along with England, Switzerland, Wales, and Montenegro. Bulgaria finished in last place in the group.


title: Bulgaria national football team

text: In the qualification phase for the 2014 FIFA World Cup in Brazil, Bulgaria were placed in Group B together with the teams of Italy, Denmark, Czech Republic, Armenia and Malta. Under the guidance of former player Lyuboslav Penev as head coach, Bulgaria enjoyed a revival and some noteworthy performances in friendly matches before the start of the qualifying, including a 2–1 victory over 2010 World Cup runners-up Netherlands in Amsterdam. The qualifying began with a 2–2 draw against Euro 2012 runners-up Italy. Bulgaria then edged a tight match against Armenia, which ended 1–0. Next, Bulgaria drew 1–1 against Denmark. Four days later, Bulgaria earning a hard-fought 0–0 draw away to the Czech Republic. As a result, the team climbed from 96th in the FIFA World Rankings, their lowest position in history, to 40th in November 2012.


title: Bulgaria national football team

text: Penev's players hosted and defeated Malta 6–0 under heavy snowfall. Four days later, Bulgaria drew Denmark 1–1 in Copenhagen. This result left Bulgaria second in the group with 10 points, still undefeated. Bulgaria traveled to Italy, losing 1–0. After a series of poor results, Bulgaria ended up failing to qualify for Brazil 2014.


title: Bulgaria national football team

text: Bulgaria were placed in a group with Italy, Croatia, Norway, Azerbaijan, and Malta. Bulgaria opened up their first match with a 2–1 victory over Azerbaijan. They were defeated 1–0 by Croatia, following another 2–1 defeat to Norway. To make it worse, Bulgaria drew with Malta 1–1 at home, which would cost manager Lyuboslav Penev his position. He was replaced by Ludogorets Razgrad manager Ivaylo Petev.


title: Bulgaria national football team

text: On his debut match, Petev's squad drew Romania 0-0; this later led to a 2–2 draw with Italy, which Bulgaria led until a last-minute Italian equalizer. Bulgaria defeated Malta 1–0 to edge two points ever closer to the third place playoff position. After a series of losses, Bulgaria failed to qualify for Euro 2016 in France despite a 2–0 defeat of Azerbaijan.


title: Bulgaria national football team

text: Bulgaria were drawn in a strong World Cup qualification group with the Netherlands, France, Sweden, Belarus and Luxembourg. They began with a 4–3 win against Luxembourg at home. This was followed by heavy losses to France (4–1) and Sweden (3–0).


title: Bulgaria national football team

text: In November 2016, the Lions beat Belarus in Sofia 1–0, and then put up one of their best performances in recent years, beating the Netherlands 2–0 to move into third place in the group.


title: Bulgaria national football team

text: Bulgaria then beat the group leaders Sweden 3–2 in Sofia to move one point behind their opponents in the table. However, they lost the match against the Netherlands at the Amsterdam Arena 3–1. A 1–0 defeat at home to France and a 1–1 draw in Luxembourg ended their chances of qualifying.


title: Bulgaria national football team

text: Bulgaria were drawn in UEFA Nations League C with Norway, Slovenia and Cyprus. Bulgaria opened up the campaign with a 2–1 win over Slovenia and a clean sheet against Norway. The Norwegians eventually avenged their loss to Bulgaria, resulting in a tie for first place. Bulgaria eventually closed out the second round of games with two 1–1 draws against Slovenia and Cyprus, resulting in a second-place finish.


title: Bulgaria national football team

text: Bulgaria was drawn in Group A with England, Czech Republic, Montenegro and Kosovo. The team began the qualifying campaign with a 1–1 home draw against Montenegro and a 1–1 away draw to Kosovo while losing three major players due to injuries. They later carried on with two more losses which sparked the end of their group campaign. Despite finishing in fourth place, the national side had one more opportunity to qualify for the Euros thanks to the good performance in the Nations League. It sent Bulgaria to the Path A qualifying play-offs, which also included Hungary, Iceland and Romania.


title: Bulgaria national football team

text: The draw put Bulgaria against Hungary in their first play-off match on their quest to qualify for a major competition since 2004. However, in front of limited number of home fans, Bulgaria fell 1–3 to Hungary, and was eliminated from the tournament.


title: Bulgaria national football team

text: After appointing Georgi Dermendzhiev as their new head coach, Bulgaria began their brief promotion in League B. Being drawn into Group 4 with Wales, Finland and Republic of Ireland, Bulgaria played its first match against Ireland. A near victory for the Bulgarians until a 90th minute injury time equalizer sealed the draw for the Irish. Bulgaria would then play away to Wales, where they held the hosts leveled 0-0 until another 90th minute injury time goal that resulted in 0–1 loss. The problems would continue with another set of narrow losses to Finland and Wales, forcing Bulgaria to miss out on promotion to League A. With two more matches left, Bulgaria finished winless against Finland and Ireland, relegating the Lions to League C.