In Salton City etc. Owners Assn. v. M. Penn Phillips Co. (1977) 75 Cal.App.3d 184, the court held at pages 188-189, that an association of persons who had entered into land sale contracts with the defendants had standing not only in a representative capacity but also was in essential nature a proper (although somewhat unorthodoxly defined) class action. The court reiterated at page 187 that a plaintiff's standing to sue as a representative should be considered in the light "of the particular plaintiff's ability to fairly protect the rights of the group he purports to represent." The court also reiterated the distinction between class and representative actions, and continued at page 191: "In either instance, however, justification for the procedural device whereby one may sue for the benefit of many rests on considerations of necessity, convenience and justice." The California Supreme Court subsequently denied a hearing in Salton City.