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==Defendant class action== 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 [[Sexual abuse scandal in the Catholic archdiocese of Portland|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.<ref>{{cite web |url=http://www.archdpdx.org/bankruptcy/news/class-action-notice.html |url-status=dead |archive-url=https://web.archive.org/web/20090106181817/http://www.archdpdx.org/bankruptcy/news/class-action-notice.html |date=August 18, 2005 |archive-date=January 6, 2009 |title=Parishioners Notified of Class Action |website=Archdiocese of Portland in Oregon}}</ref> Where both the plaintiffs and the defendants have been organized into court-approved classes, the action is called a bilateral class action. In the United States, only a few hundred defendant class actions have been filed (mostly in securities cases and constitutional challenges), and circuit courts are split as to whether injunctive relief is available against defendant classes at all.<ref>{{cite journal |title=The Overlooked Utility of the Defendant Class Action |last=Shen |first=Francis X. |journal=Denver University Law Review |volume=88 |issue=1 |date=January 2010 |page=73 |url=https://digitalcommons.du.edu/dlr/vol88/iss1/4/}}</ref>
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