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 Rule 23(a)(4) requires that the representative parties fairly and adequately protect the interests of the class. This element reflects concerns about the competency of class counsel and potential conflicts of interest: '(a) the plaintiffs' attorney must be qualified, experienced, and generally able to conduct the proposed litigation; and (b) the plaintiffs must not have interests antagonistic to those of the class.' Rosario, 963 F.2d at 1018; see General Tel. Co. v. Falcon, 457 U.S. at 157, n. 13. Courts generally presume competency of class counsel at the outset of the litigation 'in the absence of specific proof to the contrary by the defendant.' See Newberg & Conte, Newberg on Class Actions at § 3.42. 

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