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The indirect purchaser cases brought against Microsoft under state law in the wake of the government's victory in United States v. Microsoft have been certified as class actions much more frequently than other indirect purchaser cases. In this study, I explore possible explanations for this disparity, including lenient standards of certification;factual characteristics of the Microsoft cases that might be favorable to certification; and the supposed preclusive effect of findings in the government case. In the conclusion, I consider whether the certification of these cases under lenient standards has been in the public interest.