AAI filed comments with the European Commission in response to its public consultation on developing a coherent European approach to collective redress. In its comments, AAI maintained that an effective system of collective redress requires some form of "opt out" collective actions and an effective mechanism of financing such actions. AAI urged the EU not to be swayed by efforts to portray the U.S. class system as plagued by rampant class abuse. The comments highlighted the benefits of the system for antitrust, and debunked the myth of widespread class action abuse. The comments were written by AAI Director of Legal Advocacy Richard Brunell.