The 2008 collapse of hedge fund Parkcentral Global, L.P., which was managed by H. Ross Perot’s money management team, spawned a great deal of litigation.  In one branch of that litigation, certain investors sought certification of a class action in the U.S. District Court for the Northern District of Texas to pursue claims of breach of fiduciary duty against the fund’s investment managers on behalf of all affected investors.  See “Can Hedge Fund Managers Contract Out Of Default Fiduciary Duties When Drafting Delaware Hedge Fund and Management Company Documents?,” Hedge Fund Law Report, Vol. 6, No. 14 (Apr. 4, 2013).  In a recent decision, the District Court refused to certify a class because it was not impractical for the individual fund investors who suffered losses to join the suit and because common issues of law or fact did not predominate in the case.  This article describes the decision, and is relevant to those on either side of the bar – disgruntled hedge fund investors and their counsel, and those defending or managing the defense of such actions.