TAMPA, Fla. - The Florida federal judge overseeing the Accutane multidistrict litigation on Nov. 7 declined to sanction a plaintiff for his unsuccessful remand motion, saying the plaintiff simply did not understand applicable law about corporate citizenship for jurisdictional purposes (In Re: Accutane Products Liability Litigation, MDL Docket No. 2523, No. 8:08-md-2523, Kyle Berry v. Hoffman-La Roche, No. 8:13-1287, M.D. Fla., Tampa Div.).