In Farwell v. Sunset Mesa Property Owners Assn., Inc. (2008) 163 Cal.App.4th 1545, the trial court sustained a demurrer to plaintiffs-appellants' allegation of a defendant class with leave to amend for lack of a proper class representative. The appellants argued that the trial court's comments doubting their ability to amend sounded the death knell for their allegation of a defendant class, and that all the homeowners potentially would have to be brought in as defendants. Division Eight of this appellate district refused to apply the death knell doctrine and dismissed the appeal. "The gist of the death knell doctrine is that the denial of class action certification is the death knell of the action itself, i.e., that without a class, there will not be an action or actions, as is true of cases when the individual plaintiff's recovery is too small to justify pursuing the action. In this case, as inconvenient as separate individual actions against homeowners may be both for plaintiffs and defendants, such actions can nevertheless be filed and pursued. Thus, this is not an appropriate case for the death knell doctrine." (Farwell, at p. 1552.)