ORDER RE MOTION FOR CLASS CERTIFICATION

Before the Court is Plaintiff Michael Cole’s Motion for Class Certification and Appointment of Class Counsel.1 Defendant Gene by Gene opposed the motion,2 to which Mr. Cole replied.3 Oral argument was not requested and was not necessary to the Court’s decision.

BACKGROUND

Gene by Gene sells at-home DNA testing kits, which allow for comparisons between individuals to determine whether the individuals are related. There are three varieties of tests: Y-DNA, mtDNA, and autosomal DNA.4 Along with one of the three tests, Gene by Gene sends its customers an at-home testing kit containing two vials, two cheek swabs, an optional release form, a welcome letter, instructions, and a return envelope.5 The release form grants Gene by Gene permission to provide the customer’s name and email address to “genetic matches,” along with sufficient information about the customer’s DNA test results to explain the nature of the genetic matches.6 After the customer has returned the kit and the sample has been tested, the customer can *503view his results on the Family Tree DNA website.7 The customer then has the option of joining “projects,” which are websites run by volunteer administrators that allow customers to connect to individuals with similar surnames, genetic characteristics, or regional histories.8 Terry Barton, a project administrator for Gene by Gene, runs the website WorldFamilies.net, which hosts more than 1600 projects sites, and offers varying degrees of support to the volunteer administrators.9 When a customer joins a project, such as those hosted by WorldFamilies.net, Mr. Cole alleges that the customer’s name, email address, oldest known ancestor, DNA testing kit number, and DNA test results are automatically shared with the group administrators.10 Mr. Cole alleges that this information is shared without the customer’s consent. Moreover, Mr. Cole asserts that by default, customers’ kit numbers and DNA test results are posted on publicly available project websites.11 Mr. Cole specifically alleges that if a customer joins a project administered by Terry Barton, the customer’s test results and contact information are transmitted to WorldFamilies.net servers and databases, where the results may be displayed on World Families’ public website.12 Mr. Cole maintains that he is one of hundreds of individuals in Alaska who “purchased a test from Gene by Gene and joined a project, only to find that doing so had resulted in the disclosure of his Genetic Information.”13

Mr. Cole now moves the Court to certify the following class:

Project Membership Class: all individuals who purchased a DNA test from Gene by Gene, Ltd. and who executed a release form and joined a Family Tree DNA “project” between May IS, 2012 and August 1, 2016, while residing in the State of Alaska.

Mr. Cole further moves to certify the following subclass:

Worldfamilies Subclass: all Project Membership Class members who joined a Family Tree DNA “project” administrated or co-administered by Terry Barton and/or WorldFamilies.net.14

Gene by Gene opposes Mr. Cole’s motion and argues that class certification must be denied because: (1) Mr. Cole’s claim is unique: therefore, there are issues with commonality and typicality: (2) other class members might be entitled to actual damages that Mr. Cole is “expressly uninterested in representing”: (3) individual interests predominate over potential class interests and a class action is not superior to other methods to adjudicate this controversy: and (4) “the application of solely punitive damages, in the absence of alternate harm, is overly burdensome and disproportionate.”15

*504DISCUSSION

I. Jurisdiction

This Court has diversity jurisdiction pursuant to 28 U.S.C. § 1332.

II. Legal Standard

“The class action is ‘an exception to the usual rule that litigation is conducted by and on behalf of the individual named parties only.’ ”16 Pursuant to Federal Rule of Civil Procedure 23(a), a district court may certify a class only if (1) it is so numerous that joinder of all members is impracticable, (2) there are questions of law or fact common to the class, (3) the claims of the representative party are typical of the claims of the class, and (4) the representative party will fairly and adequately protect the interests of the class.

Before certifying a class, a court must also find that one of the requirements of Rule 23(b) has been meet. Here, Mr. Cole relies on Rule 23(b)(3), which requires finding (1) that questions of law or fact common to the class predominate over any questions affecting individual class members: and (2) that a class action is superior to other available methods for resolving the controversy.

The party seeking class certification “bears the burden of demonstrating that the requirements of Rule 23(a) and (b) are met.”17 “[A] district court facing a class certification motion is required to conduct ‘a rigorous analysis’ to ensure that the Rule 23 requirements are satisfied.”18 Here, as explained below, the Court finds that Mr. Cole has not satisfied the requirements of Rule 23(b)(3) — predominance and superiority— and will deny the motion on that basis.19

a. Predominance

The predominance requirement is met where the proposed class’s interests are “sufficiently cohesive to warrant adjudication by representation.”20 The presence of commonality alone, as required under Rule 23(a), is not sufficient to fulfill Rule 23(b)(3)’s predominance requirement.21 “Rule 23(b)(3) imposes a ‘far more demanding’ standard than [Rule] 23(a)(2).”22 Rule 23(b)(3) requires that common questions predominate over individual questions. To make this determination, a court “must identify the issues involved in the case and determine which are subject to generalized proof, and which must be the subject of individualized proof.”23

Mr. Cole brings this action against Gene by Gene for violating Alaska’s Genetic Privacy Act. To prevail in a class action, each plaintiff must demonstrate that Gene by Gene disclosed the results of that customer’s DNA analysis and that it did so without that customer’s informed and written consent.

Mr. Cole has demonstrated that this case involves certain questions common to the proposed class and subclass. For example, whether Gene by Gene’s DNA testing constitutes a “DNA analysis” under the Act is a *505common question that “can be resolved uniformly across the Classes.” 24 The testimony of Elliot Greenspan, creator of the software Family Tree DNA uses,25 indicates that the three types of tests Gene by Gene offers are substantially similar. Mr. Greenspan explains that all three tests take millions of data points, put them into a database, and use algorithms to match the customer with his or her genetic match.26 There is also evidence that “the information that’s available about customers’ test results” is the same, regardless of which test that customer purchased.27 And although Gene by Gene offers three different types of genetic testing, each has the same objective: matching the customer with his or her genetic matches. Accordingly, whether Gene by Gene’s DNA tests constitute DNA analyses is a common question among the proposed class members.

Whether Gene by Gene’s alleged disclosures were for profit is another question that is common to the proposed classes.28 Bennett Greenspan, Gene by Gene’s Founder and President,29 testified that when customers join projects, Gene by Gene “increases [its] ability to reach out to other potential test takers.”30

The Court agrees with Mr. Cole that whether Gene by Gene performs genetic testing and whether the alleged disclosures resulted in profit are questions common to the proposed class and subclass.

Mr. Cole also argues that “[wjhether Gene by Gene’s sharing of its customer’s Genetic Information constitutes a ‘disclosure’ is common to each member of the Glasses” because “every time a customer joined a project, the customer’s testing results were automatically provided to the relevant group administrators.” 31 But Gene by Gene responds that a project administrator’s access to a customer’s testing results depends on the privacy settings selected by the customer himself.32 Accordingly, Gene by Gene maintains that each class member would need to prove the group administrator actually logged in and accessed the results.33

To show that the alleged disclosures were uniform and automatic, Mr. Cole cites Elliott Greenspan’s deposition testimony. He testified, “[W]hen the customer’s results come back, they will get notified, the customer themselves, as well as a group administrator that is managing that sample, if there is one.”34 Mr. Greenspan did not testify that group administrators automatically receive each customer’s full test results. Rather, it appears the notification simply informs the administrator whenever “a new result has come in that matches [their group].” Whether additional information is provided depends on several factors, including whether the customer “signed the release form,” whether the customer joined any projects, and whether the customer kept his privacy settings on private, public, or group.35 These issues are *506significant aspects of the case and require individualized proof, weighing against a finding that common questions predominate.

Whether each proposed class member gave informed and written consent to disclosure could depend on several individualized determinations: whether the customer signed a release form, the precise language of that particular customer’s form, and the information provided to that customer about potential disclosures of genetic information. Bennett Greenspan testified that when a customer first orders a test kit, he or she receives a release form, which gives Family-Tree DNA the customer’s “consent to match them against other people in the database so they can see who they are related to.”36 He describes the release form as a “mutual opt-in” form. Max Blankfeld, one of the founders of Gene by Gene and its current Chief Operating Officer,37 explained that “[t]he person that did not sign the release would not have their information disclosed.”38 But the record before the Court demonstrates variations in the terms of release.39 As a result, it appears that different customers signed different forms and may have consented to different disclosures. In short, individualized determinations may be required as to the consent form each customer signed, which could be different for each project the customer joined.

The individualized proof that would be required to establish each customer’s consent, together with the individualized proof needed to demonstrate Gene by Gene’s disclosure of each customer’s test results, supports a finding that individual questions predominate over common questions, as both consent and disclosure are key elements of the Genetic Privacy Act.

Gene by Gene also argues that the “individual extent of damages is fatal to Plaintiffs certification motion.”40 It notes that this Court has previously interpreted Supreme Court precedent as requiring a plaintiff to “provide the district court with a method that is capable of measuring damages on a class-wide basis” when the class involves individual damages.41 Mr. Cole responds that “the black letter rule is that individualized damage calculations generally do not defeat a finding that common issues predominate.”42 But “in particular cases, courts may examine whether individual damage concerns are unusually pertinent or unique,” particularly where, as here, any actual damages “are not susceptible to a formulaic calculation.”43

While “damage calculations alone cannot defeat certification,” “plaintiffs must show that ‘damages are capable of measurement on a classwide basis.’ ”44 A proposed method for measuring individual damages should translate “the legal theory of the harmful event into an analysis of the economic impact of that event.”45

*507To the extent that any of the approximately 900 proposed class members sustained actual damages such as employment, health, or insurance discrimination, Mr. Cole has not proposed any method for measuring such damages. A trial within a trial would likely ensue for each class member seeking actual damages so as to establish the proximate cause of the alleged actual damages and the extent of that customer’s injury as it relates to Gene by Gene’s liability.46 While Mr. Cole does not need to show that each members’ damages are identical, he must establish a means for measuring damages on a classwide basis that is traceable to Gene by Gene’s conduct. With respect to actual damages, he has failed to present any such method.

The present case is distinguishable from the case Mr. Cole cites in his motion, Harris v. comScore, Inc.47 In Harris, each class and subclass member agreed to the same form contract and engaged in a substantively identical process when they downloaded the defendant’s software. The software then collected the same information from all computers on which it was downloaded. Based on these similarities, the district court determined that common questions predominated and class certification was appropriate.48

But here, the record indicates that proposed class members received different release forms, joined different projects run by different administrators, and could adjust the privacy settings to different degrees of disclosure. And to the extent that any of the approximately 900 proposed class members claims actual damages, such plaintiff would need to individually establish actual harm and connect that harm to Gene by Gene’s alleged violation of the Genetic Privacy Act. The potential variance among the proposed class is substantially at odds with the uniformity of the proposed class in Harris.49 For the foregoing reasons, the Court finds that Mr. Cole has not demonstrated that questions common to the class predominate over questions that require individualized proof.

b. Superiority

“The policy at the very core of the class action mechanism is to overcome the problem that small recoveries do not provide the incentive for any individual to bring a solo action prosecuting his or her rights.”50 In the superiority analysis, a court determines whether a class action is the best vehicle for the litigation of the plaintiffs’ claims. A class action is superior when the claimed damages for each individual claimant are too small to be pursued individually.51 A class action may also be superior to other forms of litigation when it “achieve[s] eco-nom[y] of time, effort, and expense” by consolidating duplicative individual lawsuits.52 In making a determination as to whether a class action is the superior method of adjudication, Rule 23(b) directs a court to evaluate the *508following four factors: (1) the class members’ interests in individually controlling the prosecution: (2) the extent and nature of any already-pending litigation concerning the controversy: (3) the desirability of concentrating claims in one judicial forum: and (4) the likely difficulties in managing a class action,

The first factor asks whether the cost of pursuing individual litigation is prohibitive, thereby rendering a class action the presumptively superior method of adjudication.53 To gauge the costs of individual suits for comparative purposes, a court may look at (1) the complexity of the underlying substantive law: (2) the litigiousness of the defendant: and (3) the ability of the plaintiff to recover attorney’s fees under the relevant statute.54 Here, unlike securities law or patent litigation, this case involves a direct application of a relatively straightforward and concise law.55 There is no indication in the record that Gene by Gene has been unduly litigious. And Alaska Rule of Civil Procedure 82 provides that “the prevailing party in a civil case shall be awarded attorney’s fees,” which may ineentivize a plaintiffs attorney to pursue this type of case.

Moreover, the available remedy under the Alaska Genetic Privacy Act for a for-profit violation would appear to be sufficient to make an individual suit economical. Mr. Cole has alleged that Gene by Gene’s violations resulted in profit, which could render him entitled to a minimum of $100,000 for his claim alone.56 His claim satisfies the $75,000 threshold for diversity jurisdiction so that it may be individually pursued in federal court. Accordingly, the Court finds that given the amount of Mr. Cole’s individual claim, this factor weighs strongly against class certification.

The second factor, the extent and nature of any already-pending litigation, is “intended to serve the purpose of assuring judicial economy and reducing the possibility of multiple lawsuits.”57 Here, neither party has apprised the Court of any other pending litigation against Gene by Gene for alleged violations of Alaska’s Genetic Privacy Act. Accordingly, there is no indication that a class action would achieve greater economy of time, effort, or expense. Therefore, this factor weighs against finding that a class action is the superior method of adjudication.

The third factor evaluates the advantages of concentrating litigation in this forum. Here, the Genetic Privacy Act is an Alaska statute and each proposed class member is an Alaska resident. And yet there is no other case of this nature pending in the District of Alaska. The Court finds that, if there were to be other claims, concentrating litigation in one class action in the District of Alaska could be desirable, unless, as discussed above, there were variations in the releases, privacy settings, actual damages sought, or other individualized determinations that made a class action unwieldy.

The fourth factor examines the difficulties in managing the class action. The Ninth Cir*509cuit has held that “when the complexities of class action treatment outweigh the benefits of considering common issues in one trial, class action treatment is not the ‘superior’ method of adjudication.”58 Here, as discussed above, there may be many individual issues that predominate in the case regarding disclosure, informed consent, and actual damages. Given this likelihood, together with the magnitude of each individual plaintiffs potential damages award, the Court does not find that Mr. Cole has demonstrated that a class action is superior.

In light of the foregoing, the Court finds that a class action is not the superior method for adjudicating this dispute.

3. Due Process Concerns

Gene by Gene also argues that “even if Plaintiff can meet his burden to establish the elements of Rule 23,” the Court should deny class certification because the potential “damages are overly excessive,”59 The Ninth Circuit instructs it is “not appropriate to evaluate the excessiveness of the award [when deciding whether to certify a proposed class].”60 This Court has carefully considered available remedies under Alaska’s Genetic Privacy Act to determine whether individual litigation or a class action is the preferable method for adjudication in this case. But the Court has not considered the distinct issue of whether the overall potential damages award at stake if the proposed class were certified would violate Gene by Gene’s right to due process.61 In light of the Court’s determination under Rule 23(b)(3), the Court does not reach this issue.

CONCLUSION

Because Mr. Cole has not established that common questions predominate and that a class action is the superior method of adjudication, the Court finds that class certification is inappropriate for the proposed Class and Subclass at this time.62 Therefore, Mr. Cole’s Motion for Class Certification at Docket 138 is hereby DENIED. The class action claims in Mr. Cole’s Complaint are DISMISSED. This action shall proceed with respect to Mr. Cole’s individual claims only.