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Data breach class actions: Third Circuit sets out parameters for Article III injury-in-fact

Takeaway:  We have written a number of articles about the kinds of intangible injuries that confer Article III standing in the data breach and credit reporting contexts.  See Data breach class actions: Southern District of...more

Wiretap class actions: Third Circuit reinstates class claims asserted under Pennsylvania’s broad wiretap act

Takeaway:  State wiretap acts have been around for a long time, and they can provide greater protection to victims of intercepted communications than the Federal Wiretap Act, 18 U.S.C. § 2510.  These statutes generally...more

Sixth Circuit grants Rule 23(f) interlocutory review in one of the largest class actions ever

Takeaway:  In the U.S. Supreme Court’s seminal decision in Wal-Mart Stores, Inc. v. Dukes, 564 U.S. 338, 342 (2011), the court described a class consisting of 1.5 million class members as “one of the most expansive” classes...more

Eleventh Circuit reinstates no-hire antitrust claims against Burger King

Takeaway: Restrictive covenants have generated a lot of controversy lately, especially with the Department of Justice’s continued focus on illegal no-poach hiring agreements between Silicon Valley companies and other firms. ...more

Eleventh Circuit emphasizes the abuse of discretion standard in affirming the denial of certification of a “diminution in value”...

Takeaway: From the perspective of attorneys representing class action defendants, it seems that some circuits (especially the Ninth Circuit) do not give much deference to district court decisions denying class certification....more

Seven Key Takeaways: Class Certification in the Ninth Circuit – Predominance

Kilpatrick Townsend partner Jay Bogan, along with three other panel members, recently presented “Class Certification after Olean v. Bumble Bee: Expert Testimony, Uninjured Class Members, and Article III Standing.” This...more

Eleventh Circuit holds that every class member must have standing for a class action settlement to be approved

Takeaway: We have posted articles addressing the U.S. Supreme Court’s standing-related decision in Frank v. Gaos, 139 S. Ct. 1041 (2019), as well as its decision in TransUnion, LLC v. Ramirez, 141 S. Ct. 2190 (2021). In a...more

Fifth Circuit refuses to address non-CAFA grounds for remand where defendant petitioned to appeal remand decision under CAFA (28...

Takeaway: The Class Action Fairness Act (CAFA) provides class action defendants with the means to secure federal jurisdiction over putative class actions filed in state court, as well as a mechanism to appeal decisions by...more

Data breach class actions: Southern District of New York dismisses action against health care providers for lack of standing

Takeaway: In a prior article, we reported on the Second Circuit’s decision in McMorris v. Carlos Lopez & Associates, LLC, 995 F.3d 295 (2d Cir. 2021), in which the court, ruling on an issue of first impression, set out a...more

En banc Ninth Circuit reinstates class certification ruling in Bumble Bee price-fixing case, arguably solidifying a circuit split...

Takeaway: A year ago we wrote about the Ninth Circuit’s decision in Olean Wholesale Grocery Cooperative, Inc. v. Bumble Bee Foods LLC, 993 F.3d 774 (9th Cir. 2021), where a panel held that a district court abused its...more

Eleventh Circuit clarifies procedural and appellate jurisdictional issues pertaining to CAFA’s local controversy exception

Takeaway:  The Class Action Fairness Act (CAFA) provides class action defendants with the means to secure federal jurisdiction over putative class actions filed in state court, as well as a mechanism to appeal decisions by...more

Data breach class actions: Fifth Circuit rules that unsecured storage leading to a breach does not constitute “knowing disclosure”...

Takeaway:  Federal and state statutes that provide minimum damages awards for each statutory violation, such as the federal Telephone Consumer Protection Act and Illinois’s Biometric Information Privacy Act, provide ideal...more

Ninth Circuit: proof of injury is a merits issue that can doom class treatment

Takeaway: When a district court certifies a damages class action, it often cites the long line of cases holding that, because damages for each class member can be determined after a class action trial on liability,...more

Eleventh Circuit: putative class action may proceed against airline that did not disclose fee in its customer contracts

Takeaway:  Adhesion contracts have become ubiquitous in modern internet commerce, and we have written a number of articles about how businesses prepare their on-line contracts to shield themselves from liability generally and...more

Tenth Circuit affirms dismissal of false advertising class action predicated on puffery

In a recent post, we reported on the Second Circuit’s affirmance of a district court order dismissing a false advertising class action based on alleged misrepresentations that amounted to nothing more than puffery. See...more

BIPA – an ideal “no injury” class action

Takeaway:  Last year, we reported on a Seventh Circuit decision endorsing a “no injury” pleading strategy for violations of Illinois’s Biometric Information Privacy Act (BIPA).  The strategy, calculated to prevent the removal...more

Ninth Circuit: class representative may not tailor class definitions to accommodate personal and not class-wide merits issues

Takeaway: The individual claims asserted by a class representative – as well as the defenses that apply to those claims – form the foundation of any effort to certify a class under Rule 23. If the claims of the class...more

Fifth Circuit examines mechanisms to secure federal jurisdiction in class action and arbitration contexts

Takeaway:  When litigating class certification and motions to compel arbitration, defense attorneys virtually always prefer federal over state courts.  In two cases involving home security provider ADT, L.L.C. (ADT), and a...more

S.D. Fla.: concealment theory warrants class treatment under FDUTPA but not RICO

Takeaway:  Class actions brought under federal RICO present significant risks for defendants.  They present the opportunity for certification of nationwide or multi-state classes under a federal statute, and the remedies...more

Ninth Circuit holds product label preemption defense requires evidence and does not extend to materially-different statements on...

Takeaway: The quickest, most efficient way to kill a putative class action remains a successful Rule 12 motion to dismiss. But in ruling on such a motion, a district court generally cannot stray beyond the allegations in...more

Eleventh Circuit distills federal preemption, FDUTPA safe harbor, and damages issues in Bombay Sapphire Gin putative class action

Takeaway: Antiquated laws can give rise to creative class actions. In the nineteenth century, the Florida Legislature criminalized the use of a food ingredient ultimately declared safe for consumption by the Food and Drug...more

Ninth Circuit: California antitrust law does not apply to the claims of a nationwide class

Takeaway: Consumer class actions primarily target a damages remedy. In the antitrust context, state antitrust law provides the path to damages for indirect purchasers, because federal antitrust law bars indirect purchaser...more

Third Circuit examines propriety of issue certification under Federal Rule 23(c)(4)

Takeaway: Federal Rule 23(c)(4) provides: “When appropriate, an action may be brought or maintained as a class action with respect to particular issues.” Although class plaintiffs often seek “issue certification” as an...more

Third Circuit forbids “one-way intervention” in cases combining FLSA opt-in collective claims with Rule 23 opt-out claims

Takeaway: In theory, class litigation should be fair. Class members should not be permitted to see how a case will play out at trial before deciding whether to opt out of a damages class – a practice known as “one-way...more

Second Circuit false advertising class actions predicated on puffery are doomed to fail

Takeaway: Although a district court deciding a Rule 12 motion to dismiss must draw every inference in favor of a plaintiff, courts know puffery when they see it. In George v. Starbucks Corp., --- Fed. Appx. ----, No....more

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