In this chapter, the author further explores the connection between the preclusive doctrines of collateral estoppel, stare decisis and virtual representation. It points out how stare decisis can be used in the place of virtual representation as a tool to reduce litigation on the same questions of law leading to the same outcomes that could be obtained with virtual representation, according to the view endorsed by the Supreme Court of the United States. It also argues there is a substantial difference between collateral estoppel and stare decisis in any preclusive function: the first only applies when the party against whom preclusion is asserted fully litigated the issue before, the latter need only to reflect a court’s majority understanding on a question of law and can be asserted against anyone, regardless of whether they litigated before.