The Seventh Circuit Court of Appeals recently invalidated a nationwide settlement agreement covering six consumer fraud class actions (“Settlement Agreement”) brought against NBTY, Inc., Rexall Sundown, Inc., and Target Corporation (“Defendants”).  See Pearson v. NBTY, Inc., No. 14-1198 (decided Nov. 19, 2014).  Each case was premised on Defendants’ allegedly deceptive marketing and sale of