California's Fourth District Court of Appeal Applies the "Injury in Fact" and "Causation/Reliance" Elements of the UCL Standing Requirement to Uphold Dismissal of UCL Claim at Pleading's Stage


On January 7, 2008, the California Court of Appeal, Fourth District, issued an opinion upholding the dismissal (on demurrer) of a purported class action brought under the California Unfair Competition Law, Bus. & Prof. Code § 17200 et seq. (?UCL?), based on the application of the UCL?s standing requirement of ?injury in fact? and causation. Hall v. Time Inc., --- Cal.App.4th ----, 2008 WL 68631 (Jan. 7, 2008). The decision further underscores the usefulness of the UCL standing requirement in obtaining dismissal ? in some cases with prejudice ? of inadequate UCL claims at the pleadings stage, and is thus good news to UCL defendants seeking viable defenses to be used in moving for early stage dismissal.

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