Whether class-action statute-of-limitations tolling under American Pipe & Constr. Co. v. Utah should continue until a district court's denial of class certification is affirmed on appeal

QUESTIONS PRESENTED FOR REVIEW 1. Whether class-action tolling under American Pipe & Constr. Co. v. Utah, 414 U.S. 538 (1974), should continue until a district court’s denial of class certification is affirmed on appeal. 2. Whether the fact that a district court grants a party’s motion for sanctions necessarily precludes the court from granting the sanctioned party’s crossmotion for sanctions where the cross-motion was based primarily on misrepresentations in the first motion. 3. Whether a district court may impose, upon an attorney, sanctions based on the district court’s finding that the bringing of the district-court action was frivolous because a precedent of the instant circuit court was binding (in the district court’s view) and thus barred the plaintiff*s claims, even though: (i) the precedent had been decided in a different factual context; (ii) the plaintiff exercised, with respect to his claims, the right to assert them and make corresponding arguments in order to preserve such claims and arguments for further appellate review in the event that the district court were to find that the arguments, and thus the claims, were foreclosed by binding circuit precedent: (ii) neither the circuit court en banc nor this Court had ever been presented with, much less rejected, the party’s arguments; and (iv) the district court acknowledged that the party’s arguments were not substantively frivolous. i