Eleventh Circuit Holds that a Statutory Violation is Insufficient for Standing and Settlement

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In Muransky v. Godiva, the Eleventh Circuit held that a violation of the Fair and Accurate Credit Transactions Act (“FACTA”) was insufficient to allege a concrete injury for standing purposes.

Background

Dr. David Muransky filed a class action complaint against Godiva Chocolatier after he received a printed credit card receipt that contained credit card information in excess of the permissible number of digits under FACTA. One of the goals of FACTA is to prevent identity theft. In seeking to achieve that goal, FACTA restricts anyone conducting credit card transactions for business from printing more than five digits of a card number on a receipt. Dr. Muransky, on behalf of approximately 350,000 similarly situated people, alleged that Godiva printed more than the allowed five digits in violation of FACTA.

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