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Don't miss the chance to strike out class actions

Takeaway: Many courts instinctively have a negative view of motions to strike. For decades courts have referred to such motions – at least when directed to individual allegations under Rule 12(f) – as “disfavored,” a...more

Seventh Circuit holds Zestimates constitute non actionable opinions

Takeaway: A consumer fraud class action must be grounded on allegations of false or deceptive statements of fact. Opinions, includes estimates clearly labeled as estimates, do not constitute statements of fact that can...more

Is standing overrated? Data breach defendants who lose standing battles end up winning dismissal

Takeaway: In the wake of Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016), defendants in data breach class actions regularly move to dismiss on standing grounds, arguing the complaint’s allegations do not plausibly allege an...more

Second Circuit False labeling class actions viewed in context is the theory of deception

Takeaway: In two recent cases, the Second Circuit explored the plausibility of theories of deception in false labeling/consumer fraud cases. In one case, the appellate court ruled that a plausibly false labeling statement...more

Arbitration Justice Kavanaugh eliminates wholly groundless exception to delegation clauses

Takeaway: Justice Kavanaugh’s first Supreme Court opinion is yet another High Court reminder that, when it comes to arbitration, the contract controls. If parties agree that an arbitrator should resolve the “gateway” issue...more

U.S. Supreme Court puts class action doubleheader on the calendar – cy pres awards and class arbitration

Takeaway: On April 30, the U.S. Supreme Court granted certiorari in a Ninth Circuit case approving a cy pres-only class action settlement. As we reported in a May 2018 post [U.S. Supreme Court puts class action doubleheader...more

The Lamps Plus oral argument suggests the U.S. Supreme Court may address the threshold issue of an arbitrator’s power to...

Takeaway: As we explored in a prior post (“Class arbitration – can it even work?”), conducting a class arbitration like most class actions – that is, giving absent class members notice and an opportunity to opt-out – may not...more

Reading between the lines: the Seventh Circuit’s recent class arbitrability ruling suggests a paradigm for squaring delegation...

Takeaway: In the wake of the U.S. Supreme Court’s continued vigorous enforcement of class action waivers, more and more corporate parties can be expected to include broad class action waivers in their contracts with consumers...more

First Circuit addresses an issue that continues to vex (and split) the circuits: should a class be certified that includes...

Takeaway: The issue of how to treat uninjured class members continues to vex the federal courts. This issue presents both substantive and procedural complexities. Substantively, a class must be defined in objective terms, so...more

Ninth Circuit rules that post-removal attorneys’ fees count towards CAFA’s $5 million threshold, creating split with Seventh...

Takeaway: When a plaintiff files a class action in state court, the first thing defense counsel will do is evaluate whether it can be removed to federal court. Most courts have long agreed that compensatory damages must be...more

Class arbitration – can it even work?

Courts continue to devote a lot of attention on the area of class arbitration. The U.S. Supreme Court has a case on its docket, the Eleventh Circuit just decided an issue of first impression, and another important case is...more

S.D.N.Y. rules “objector extortion” in class settlement context can and should be sanctioned, and further curtailed by requiring...

Takeaway: Where a class settlement is reached, objectors may be lurking, oftentimes to extort personal payments. Earlier this year, the Seventh Circuit termed this practice “objector blackmail.” Judge Rakoff of the Southern...more

Contradictory testimony dooms class certification of Krazy Glue “slack-fill” class action (C.D. Cal.)

Takeaway: Creative legal theories are easier to allege than prove. And a putative class representative does not always make the best deponent, especially when it comes to substantiating the key allegations in an unfair and...more

Cutting a class defendant some slack: the S.D.N.Y. rejects a “least sophisticated consumer” test in dismissing “slack-fill” class...

Takeaway: There has been a proliferation of “slack-fill” class action litigation. These cases are premised on the notion that a large product container deceives a reasonable consumer, under the theory a reasonable consumer...more

RICO class actions: To win certification, the RICO claims must be driven by defendant-specific and not class-member specific...

Takeaway: RICO actions tend to be complex. RICO class actions add to the complexity, because class counsel must figure out a way to persuade a court that common issues predominate over individual ones. This is a challenge,...more

Data breach class actions: Georgia appellate court again rejects negligence claim predicated on alleged duty to safeguard personal...

Takeaway: Data breaches are now a fact of life, whether for card-carrying consumers or commercial entities victimized by hacking or otherwise required to deal with the consequences. Class action litigation often ensues, where...more

Ninth Circuit deepens Circuit split by holding inadmissible evidence can be considered in resolving class certification

Takeaway: The Ninth Circuit recently ruled that inadmissible evidence may be considered in ruling on a motion for class certification. But does inadmissible evidence really qualify as evidence? Notwithstanding the evidentiary...more

U.S. Supreme Court puts class action doubleheader on the calendar – cy pres awards and class arbitration

On April 30, the U.S. Supreme Court granted certiorari in two class action cases, on issues involving cy pres awards and class arbitration. Both cases arise out of the Ninth Circuit. The Supreme Court’s decision in the cy...more

Seventh Circuit: the economic loss doctrine precludes tort claims between participants in a contractual network that allocates...

Takeaway: Data breaches are now a fact of life, whether for card-carrying consumers or commercial entities that are either victims of hacking or otherwise required to deal with the consequences. Class action litigation often...more

Leveraging Comcast – beating predominance where challenged product has some value

Takeaway: Alleging a “price premium” or “benefit of the bargain” damages theory is one thing. Proving it is another. A recent decision by Judge Lucy Koh of the Northern District of California shows the difficulty of...more

Ninth Circuit: If You Want An Arbitration Agreement Enforced, Don’t Try To Slide It By Later

Takeaway: If you want to avoid exposure to class action litigation, you might think about putting an arbitration clause and class action waiver in your consumer-facing terms and conditions. But if you want those terms and...more

We don’t know where we stand – three recent takes on injunctive relief standing in the Ninth Circuit

Takeaway: “Most courts to have considered the issue agree . . . that consumer plaintiffs cannot pursue injunctive relief if they are already aware of the alleged deceptive practice.” Ulrich v. Probalance, Inc., No. 16 C...more

The Spokeo Saga Continues: Ninth Circuit Finds That Incorrect Consumer Report About Age, Marital Status, Wealth, Education Level,...

Takeaway: In Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016) (“Spokeo II”), the Supreme Court ruled that not every statutory violation gives rise to a concrete injury for standing purposes. An inaccurate report of a person’s...more

The Ninth Circuit Affirms District Court’s Dismissal Of Putative Class Action Where Named Plaintiff Lacked Standing To Assert...

Takeaway: While courts continue to grapple with efforts by class action defendants to “pick off” a named plaintiff by mooting his or her individual damages claim, class representatives pressing claims for injunctive and...more

What does Spokeo mean? The Eleventh Circuit’s Unusual Debate about the U.S. Supreme Court’s Controversial Decision

Takeaway: The decision in Spokeo, Inc. v. Robins, 136 S. Ct. 1540 (2016), where the U.S. Supreme Court evaluated Article III standing in the context of a federal statutory violation, continues to generate controversy. Since...more

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