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Fifth Circuit affirms district court’s striking of class allegations and dismissal of inadequately alleged fraud-based claims

Takeaway:  We have written several articles about motions to strike class action allegations. See, e.g., Motions to strike: Eighth Circuit reverses district court refusal to strike class allegations (July 29, 2021).  In a...more

Ninth Circuit rules that excessive, aggregated awards of statutory damages are subject to review on constitutional due-process...

Takeaway: Statutes that impose per-violation statutory damages, like the Telephone Consumer Protection Act (TCPA), can lead to astronomical class action verdicts. In Wakefield v. ViSalus, Inc., 51 F.4th 1109 (2022), a Ninth...more

12/21/2022  /  Damages , Due Process , Statutory Damages , TCPA

SCOTUS grants cert. to determine whether an appeal of an order denying a motion to compel arbitration automatically stays district...

Takeaway: To control litigation risk, a business might include an arbitration clause and class action waiver in its consumer-facing terms and conditions. When a consumer files a putative class action against that business,...more

Data breach class actions: Ninth Circuit addresses forum selection and personal jurisdictional issues in case against foreign...

Takeaway:  Businesses oftentimes rely on contractual provisions to shield themselves from litigation risk.  But some provisions are more effective than others.  In Baton v. Ledger SAS, No. 21-17036, 2022 WL 17352192 (9th Cir....more

Fifth Circuit: civil RICO class action against Southwest Airlines and Boeing cannot stand for lack of Article III injury-in-fact

Takeaway: Over two years ago, the Eastern District of Texas denied a motion to dismiss a putative civil RICO class action alleging an “overcharge-by-fraud” theory, where the class representatives appeared to have suffered no...more

Data breach class actions: SDNY finds standing based on sketchy injury-in-fact allegations

Takeaway: Ever since the U.S. Supreme Court ruled in Clapper v. Amnesty Int’l USA, 568 U.S. 398, 416 (2013), that plaintiffs “cannot manufacture standing merely by inflicting harm on themselves based on . . . hypothetical...more

Middle District of Georgia dismisses putative class action against State Farm for failure to comply with “appraisal” condition...

We have written about class actions filed against State Farm and other carriers alleging systematic undervaluation of damaged vehicles. See, e.g., Eleventh Circuit emphasizes the abuse of discretion standard in affirming the...more

Data breach class actions: District of Massachusetts dismisses complaint for failure to allege injury-in-fact

Takeaway:  We have written a number of articles about standing issues arising in data breach class actions.  See, e.g., Data breach class actions: Third Circuit sets out parameters for Article III injury-in-fact (Oct. 27,...more

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

SCOTUS displays short memory in rejecting the prejudice requirement for waivers of the right to arbitrate

Takeaway: In Morgan v. Sundance, Inc., --- S. Ct. ----, No. 21-328, 2022 WL 1611788 (May 23, 2022), the Supreme Court rejected the arbitration-specific rule requiring a finding of prejudice for a waiver of the right to...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

BIPA class actions – liability of third-party vendors

Takeaway: We have written a number of articles about the explosion of class action litigation under Illinois’s Biometric Information Privacy Act (BIPA). See BIPA – an ideal “no injury” class action (Feb. 9, 2022) and BIPA...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

Internet contracts – beyond clickwrap and browsewrap

Takeaway: Technology advances. Business processes evolve. Internet transactions become increasingly ubiquitous. Contract formation, however, remains an old-fashioned concept. An internet consumer must, at a minimum, be...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

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