On October 11, the Northern District of California dismissed a sprawling 14-state, 46-count putative class action in which the plaintiffs alleged that Apple computers were defective.

• The plaintiffs alleged that Apple’s computers lacked a filter that would prevent dust and debris from clouding the computers’ screens and slowing down their processing speed. According to plaintiffs, Apple failed to disclose this alleged defect in full and instead advertised its computers as reliable, durable, high quality, and with “clear” and “remarkably vivid” screens. Apple also advertised that its computers underwent “rigorous testing.”
• The plaintiffs hailed from 14 states and sought to represent a class of all consumers who purchased Apple computers between March 2011 and April 2018. They alleged fraud and consumer protection law claims based on Apple’s purported misrepresentations about its computers and alleged concealment of the defect.
• The court dismissed plaintiffs’ claims based on three key rulings.
  • First, it found that the plaintiffs failed to show any affirmative misrepresentations because most of the statements plaintiffs relied on relating to quality and durability were non-actionable puffery. Although the statement concerning rigorous testing was not puffery, the court found that it was not false because the plaintiffs never alleged that Apple did not test its products.
  • Second, the court found that the plaintiffs failed to plead a viable omission-based theory. It rejected the argument that Apple’s limited disclosure of the defect in a user guide deceived consumers into thinking that the defect was rare, as the plaintiffs never alleged that they read the disclosure. The court also found that the plaintiffs failed to show that Apple knew that the defect would impact the motherboard, rejecting allegations based on consumer complaints because those complaints did not identify the specific filter defect.
  • Third, the court found that Apple had no duty to disclose the alleged defect. Under California law, there was no duty to disclose because the filter defect did not impair the computers’ central function or endanger consumers. Under other states’ laws, Apple did not have a duty to disclose based on superior knowledge, as there were no allegations concerning what information Apple possessed or why the plaintiffs could not discover it. Finally, plaintiffs failed to allege any intentional acts of concealment.
• The case is Ahern v. Apple Inc. Read more here.