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

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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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