A court administering a multi-district litigation proceeding has the power to require common fund benefit assessments–i.e., payments into the MDL proceeding’s common benefit fund–from recoveries in non-MDL cases if (1) counsel for claimants in a non-MDL case voluntarily consents to the district court’s authority by signing, or otherwise entering into, a participation agreement requiring contributions in exchange for access to common benefit work product, (2) that participation agreement is incorporated into a court order, and (3) as a result of entering the participation agreement, counsel receives access to common benefit work product.