The Supreme Court has largely eliminated the possibility of statistical adjudication, leaving victims of mass torts with limited avenues for recovery. Efforts to revive random sampling within class actions are unlikely to succeed given the Court’s fundamental opposition to determining liability or damages based on statistical models without individualized evidence. This Article proposes a novel approach: applying random sampling outside the class action framework through private ordering among plaintiffs who voluntarily aggregate their claims. Plaintiffs can form litigation-sharing agreements, partnerships, or trusts to create a single juridical entity that owns multiple claims. Within this aggregated lawsuit, random sampling can be employed to select representative cases for evidentiary presentation. This method aligns with established evidentiary principles permitting survey evidence and does not require doctrinal innovation or legislative intervention. The approach provides a means of vindicating legitimate claims that are too heterogeneous to benefit from the class action mechanism.