The Plaintiff brings this action on her behalf and on behalf of all other similarly affected individuals as members of the proposed Class, hereinafter collectively referred to as the “Class” or the “Class Members” which are intended hereafter to include all of the following individuals, defined as follows:
 
Newfoundland and Labrador Class Members
The Plaintiff is representative of a class of persons, resident or situated in Newfoundland and Labrador, more particularly described as follows:

(a) Any person, or if deceased their personal representative, in Newfoundland and Labrador, who is taking, or has taken, Avandia and has suffered, or will suffer, from one or more medical problems, including, but not limited to, heart failure or adverse cardiovascular events that may lead to death, heart attack or myocardial infarction (MI), renal or kidney failure, hepatitis, edema, anemia, frozen shoulder, weight gain or obesity, blindness or vision problems; or any person in Canada but outside Quebec, who suffered or will suffer from one or more of the above-mentioned medical problems.

Non-Resident Class Members
The Plaintiff is representative of a class of persons, not resident or situated in the Province of Newfoundland and Labrador or Quebec, but who are resident or situated in another Canadian province or territory, more particularly described as follows:  

(a) Any person, or if deceased their personal representative, in Canada, but not in the Province of Newfoundland and Labrador or Quebec, who is taking, or has taken, Avandia and has suffered, or will suffer, from one or more of the medical problems, including, but not limited to, heart failure or adverse cardiovascular events that may lead to death, heart attack or myocardial infarction (MI), renal or kidney  failure, hepatitis, edema, anemia, frozen shoulder, weight gain or obesity, blindness or vision problems; or who suffered or will suffer from one or more of the above-mentioned medical problems.