Due process requires that the class representative not have interests that are adverse to the class members he represents. There must be no actual or potential conflicts of interest. Under federal rules, the adequacy of representation is tested prior to certifying the action as a class action, and again when the suit is over. Adequacy of representation is examined much more closely in a defendant class action than under a plaintiff class action. There is a strong risk that the plaintiff will pick the weakest member to represent the class. In addition, there is no financial incentive for the defendant class representative to defend with determination.