I've got a rhetorical question for you: WHY?

The key and foremost issue in this case, at the class certification and liability stages, is what was the mindset and intent of [defendant] when issuing said lease agreements to optometrists; put another way, what did [defendant] know about what it was trying to accomplish by utilizing such leases, and when did they know it?

Counsellor, what do you know about what you're trying to accomplish?

Res Ipsa Loquitard

"When reviewed in accordance with the facts in the Forte and Hood and Rast cases and the above legal authorities, the question is presented - what difference results in deciding the issues surrounding Plaintiff's motion to consolidate, whether in the manner in which Plaintiff seeks or in the manner in which Defendant seeks? The answer is none, with one big exception."