In federal courts and state courts that follow federal rules, a class less than 40 would never get certified. Even if you get more than 100 and convince the court to certify as damage class under federal rule 23(b)(3), there are tremendous difficulties in notification that individual class members can be ascertainable using reasonable efforts must be notified and given option to opt out, which means any one did not get the samsung rebate could be potentially a class member because the lawsuit will bind on them, and you must notify them by mail or publication. Spending millions of dollars in notification and discovery just for $60 rebate? Why don't you report to BBB or something?