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they need not be substantially identical." 137 Thus, "even relatively pronounced factual differences" between the named plaintiff's claims and those of the class members "will generally not preclude a finding of typicality where there is a strong similarity of legal theories." 138 Many courts, when evaluating whether a proposed class action satisfies the typicality requirement, also inquire whether the proposed class representative's claim "arises from the same event or practice or course of conduct that gives rise to the claims of other class members." 139 In this respect, the typicality requirement "tend[s] to merge" with the commonality requirement, 140 which likewise examines whether "the same conduct or practice by the same defendant gives rise to the same kind of claims from all class members." 141 Other courts have suggested that typicality overlaps with the "adequate representation" requirement discussed below, 142 which similarly seeks to ensure that representative parties "adequately protect the interests of the class." 143 Fourth, a plaintiff must demonstrate that "the representative parties will fairly and adequately protect the interests of the class." 144 This prerequisite is alternatively known as the "adequacy of representation" requirement, 145 the "adequate representation" requirement, 146 or just the "adequacy" requirement

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