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Ninth Circuit reexamines California’s McGill rule – which prohibits contractual waivers of “public injunctive relief” – through...

Takeaway: One would think that “public injunctive relief” – especially under California law – would be a broad remedy. Not so, according to the majority opinion in Hodges v. Comcast Cable Communications, LLC, --- F.4th...more

Second Circuit rules Trump parties forfeited arguments on appeal

Takeaway: The importance of preserving issues for appeal when litigating a case before a trial court – from the outset of the case all the way through post-trial motions – cannot be overstated. As a general matter, a...more

M.D. Pa. orders the production of cybersecurity report in data breach class action

Takeaway: Counsel for companies that suffer a data breach often hire an outside cybersecurity firm to remediate the breach and assist counsel in preparing for and defending against litigation. These companies typically take...more

Navigating Jurisdictional Issues In Class Action Litigation

Takeway: Class action litigation implicates jurisdictional issues in a number of ways. Class action defendants generally prefer federal over state courts and – when presented with the opportunity – will seek to remove...more

False advertising class actions – absent evidence that reasonable consumers were likely to be misled, Seventh Circuit affirms...

Takeaway: To survive summary judgment, a false-advertising plaintiff must offer evidence that the challenged representations are likely to mislead a reasonable consumer. In Weaver v. Champion Petfoods USA Inc., --- F.4th...more

Data interception class actions – S.D. Fla. dismisses claim that use of session replay software violates Florida Security of...

Takeaway: As we reported in a recent article – New Class Action Trend: Website Session Replay Tools Alleged to Violate All-Party Consent Recording Requirements (April 5, 2021) – creative class action lawyers have filed a...more

SCOTUS standing ruling – “No concrete harm, no standing” – sidesteps class action issues and could limit federal subject matter...

Takeaway: In TransUnion LLC v. Ramirez, --- S. Ct. ----, No. 20-297, 2021 WL 2599472 (June 25, 2021), the Supreme Court granted certiorari to resolve the question of “[w]hether either Article III or Rule 23 permits a damages...more

Eleventh Circuit affirmance of fee award demonstrates the long reach of an MDL

Takeaway: When the Judicial Panel on Multidistrict Litigation (JPML) consolidates cases and transfers them to a single, multidistrict litigation (MDL) court, the process is in a very important respect coercive. Counsel for...more

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

Takeaway: Since the U.S. Supreme Court addressed the issue of standing based on allegations of possible future injury in Clapper v. Amnesty International USA, 568 U.S. 398 (2013), the courts of appeals have addressed this...more

Data breach class actions: M.D. Fla. threads the Rule 23 needle in certifying the first consumer payment card class action

Takeaway: Judge Timothy Corrigan of the Middle District of Florida recently found a way to certify a class action where consumers alleged the theft of payment card data, acknowledging he “may be the first to certify a Rule...more

Antitrust class actions: Ninth Circuit rules that predominance “cannot be outsourced to a jury”

Takeaway: We have posted a number of articles about whether Rule 23’s predominance requirement can be satisfied when a proposed class includes uninjured class members. See, e.g., D.C. Circuit denies class certification...more

Ninth Circuit divided panel revives krab mix false advertising class action

Takeaway: Context matters in false advertising class actions. Factors such as how an allegedly false representation is displayed, where it is displayed, and what else is disclosed on the label or advertisement all can...more

Ninth Circuit holds public injunctive relief may be pursued by an individual in arbitration, thereby enforcing arbitration...

Takeaway: One of the most effective tools for a business to reduce its exposure to class action litigation is to include compulsory arbitration provisions and class action waivers in customer-facing contracts. But there are...more

RICO class actions Ninth Circuit affirms dismissal of civil RICO claims by Volkswagen dealers

Takeaway: Class actions brought under federal RICO present significant risks for defendants. They present the opportunity for certification of a nationwide class under a federal statute, and the remedies provided under...more

BIPA class actions: Seventh Circuit endorses pleading strategy calculated to avoid removal to federal court

Takeaway: As Judge Diane Wood of the Seventh Circuit recently observed in a putative class action alleging violations of Illinois’s Biometric Information Privacy Act (BIPA), “allegations matter” and “a plaintiff is the...more

SCOTUS grants certiorari to resolve critical class action standing issue

Takeaway: In a prior article – Class action standing: Ninth Circuit holds members of a damages class must demonstrate Article III standing (March 31, 2020) – we discussed the Ninth Circuit’s decision in Ramirez v....more

CAFA: in opinion potentially at odds with two recent pro-removal decisions, Ninth Circuit rules that putative class action must be...

Takeaway: In a prior article – Ninth Circuit: two pro-defendant decisions clarify burdens regarding CAFA’s $5 million jurisdictional threshold (September 14, 2020) – we examined two recent Ninth Circuit cases where the...more

BIPA class actions: Seventh Circuit holds that retention of “inherently sensitive” biometric data gives rise to standing

Takeaway: Article III standing requires an injury-in-fact. To allege an injury-in-fact, a claimant must show “‘an invasion of a legally protected interest’ that is ‘concrete and particularized’ and ‘actual or imminent, not...more

Motions to strike class allegations: Ninth Circuit vacates order striking class allegations, ruling class discovery must go...

Takeaway: In a prior post, we reported on a Central District of California decision granting an early motion to strike class allegations. Don’t miss the chance to strike out class actions (Feb. 27, 2019). But on appeal,...more

SCOTUS declines review of Second Circuit ruling endorsing class arbitration

Takeaway: The concept of class arbitration has endured stiff headwinds. In Lamps Plus, Inc. v. Varella, 139 S. Ct. 1407 (2019), the Supreme Court ruled that a party cannot be required to participate in a class arbitration...more

Third Circuit weakens ascertainability requirement by lowering evidentiary bar

Takeaway: The Circuits have split on the issue of whether a class representative must show the class is “ascertainable.” The Third Circuit has required a Rule 23(b)(3) class to be “currently and readily ascertainable.” ...more

Ninth Circuit: two pro-defendant decisions clarify burdens regarding CAFA’s $5 million jurisdictional threshold

Takeaway: Class defendants prefer federal court. In any putative class action filed in state court, the first issue to analyze is whether the case can be removed to federal court, and any such analysis typically involves...more

9/14/2020  /  CAFA , Class Action , Jurisdiction , Remand , Removal

Consumer class actions – Ninth Circuit holds that federal and not state law controls the award of equitable restitution under...

Takeaway: Federal courts sitting in diversity are supposed to apply state law. There is a critical distinction, however, between substantive rights created by state law, on the one hand, and remedies (especially equitable...more

Fraud class actions: Ninth Circuit vacates $24 million class judgment on standing and predominance grounds

Takeaway: Class actions present significant risk, because a certified class exposes a class defendant to class-wide liability. Most defendants agree to settle rather than face the risk of a class verdict. But sometimes a...more

RICO class actions: District of New Jersey dismisses with prejudice federal RICO claims asserted by indirect purchasers

Takeaway: Class actions brought under federal RICO present significant risk, because they present the opportunity for certification of a nationwide class under a federal statute and the remedies provided under federal RICO –...more

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