IQVIA, Inc., a federal judge in Illinois struck a class definition encompassing out-of-state class members allegedly injured by junk faxes under the Telephone Consumer Protection Act. Both cases aim to resolve a question left open by the landmark ruling in BMS, in which the Supreme Court held that state courts (including those presiding over sprawling mass tort proceedings) cannot exercise personal jurisdiction over out-of-state defendants when the plaintiffs' claims arise outside the forum state. In the wake of that decision, district courts have struggled to determine whether the holding in BMS applies to unnamed, absent class members. The district court in Molock held that the claims of unnamed, out-of-state class members were not barred by BMS, while the district court in Mussat reached the opposite conclusion.