"In applying this standard, the Fourth Circuit has bifurcated the analysis into consideration of fairness, which focuses on whether the proposed settlement was negotiated at arm's length, and adequacy, which focuses on whether the consideration provided the class members is sufficient."

Common issues of law and fact have been held to predominate "where the same evidence would resolve the question of liability for all class members."

The Court assesses the adequacy of the settlement through the following factors: "(1) the relative strength of the plaintiffs' case on the merits,(2) the existence of any difficulties of proof or strong defenses the plaintiffs are likely to encounter if the case goes to trial,(3) the anticipated duration and expense of additional litigation,(4) the solvency of the defendants and the …

"Courts generally agree," however, that a class definition may be narrowed to "reflect a sharpening of the issues based on discovery and other developments in the course of litigation and settlement negotiations."

In assessing this factor, courts consider the uncertainties of litigation and compare the settlement to potential future relief.

T] he settlement terms reflect plaintiffs' counsel's consideration of the strength of their case, and the delay and cost of proceeding to trial balanced against the certainty, relative promptness, and amount of relief the settlement provides

Plaintiffs are simply narrowing their breach of contract theory at this juncture based on factual developments that have occurred since the filing of the complaint.