News & Analysis as of

Ascertainable Class

Robinson Bradshaw

North Carolina Supreme Court Requires Ascertainability for Class Actions

Robinson Bradshaw on

In earlier posts, we’ve discussed a hotly debated topic in class-action law: ascertainability. One of those posts described a case where a procedural hiccup denied the North Carolina Supreme Court a chance to address this...more

Troutman Amin LLP

CLASS IS STILL OUT: Court Again Affirms Denial of Class Certification in TCPA Lawsuit

Troutman Amin LLP on

Hi TCPAWorld! It seems that at the same time students are out of school for a break, motions for class certification are denied. Such is the case for the plaintiff in Brian J. Lyngas, D.D.S., P.L.L.C., v. IQVIA, INC., 2025 WL...more

Kilpatrick

Eighth Circuit issues pro-defendant class certification ruling in consumer fraud MDL

Kilpatrick on

Takeway:  Fraud claims are not typically suitable for class treatment, because the essential element of reliance is usually a fact-intensive, individualized issue.  When it comes to consumer fraud statutes, however, consumer...more

Troutman Amin LLP

CLASS IS NOT IN SESSION: Court Affirms Denial of Class Certification In TCPA Lawsuit

Troutman Amin LLP on

Hi TCPAWorld! Defendant just scored a huge victory with a Court affirming a denial of class certification in their lawsuit. In Brian J. Lyngas, D.D.S., P.L.L.C., v. IQVIA, INC., 2025 WL 3565507 (E.D. PA Dec 12, 2025),...more

Troutman Amin LLP

MEDICREDIT’S MOTION DENIED: Judge Refuses To Exclude Class Notice Expert And Blesses Reverse Lookup Methodology

Troutman Amin LLP on

Hi TCPAWorld! Lei here with my first blog! And it’s regarding a huge ruling out of the Eastern District of Missouri yesterday, December 9, 2025, in Saggio & Furr v. Medicredit, Inc.—a putative TCPA class action....more

Shook, Hardy & Bacon L.L.P.

Class Action Decisions Published November 2025

Highlights from this issue include: Class Action Fairness Act Jurisdiction. The Ninth Circuit held that a plaintiff’s decision to remove class allegations after a case is removed from state court to federal court deprives the...more

Troutman Amin LLP

SETTLEMENT REJECTED: $700k TCPA/CEMA Resolution Deemed Insufficient By Court

Troutman Amin LLP on

A common TCPA issue when state Mini-TCPA statutes are involved is determining who is subject to the state laws given that cell phone users might use area codes for a state but not live in that state....more

Mintz - Technology, Communications & Media...

Telephone and Texting Compliance News: Litigation Update — September 2025

In a notable ruling for Telephone Consumer Protection Act (TCPA) litigation, the U.S. Court of Appeals for the Fourth Circuit recently affirmed a district court’s decision to exclude a plaintiff’s expert witness and deny...more

Shook, Hardy & Bacon L.L.P.

Class Action Decisions Published June 2025

The full text of each summary can be found below through the Table of Contents links. Highlights from this issue include: Uninjured Class Members. The Supreme Court had originally granted a writ to decide whether federal...more

Robinson Bradshaw

Will the Supreme Court Weigh In on Ascertainability?

Robinson Bradshaw on

We’ve written previously about courts’ differing approaches to ascertainability — an implicit requirement under Rule 23 that class members must be identifiable. A pending petition for certiorari in Career Counseling, Inc. v....more

Kilpatrick

Sixth Circuit vacates certification of ten statewide classes against Nissan based on district court’s failure to ascertain common...

Kilpatrick on

Takeaway: The Sixth Circuit recently emphasized how demanding Rule 23’s commonality requirement can be. In In re Nissan North America, Inc. Litigation, --- F.4th ----, No. 23-5950, 2024 WL 4864339 (6th Cir. Nov. 22, 2024),...more

Carlton Fields

Classified (Bi-)Monthly: A Roundup of Class Action Decisions From Federal Appellate Courts July and August 2024

Carlton Fields on

The Roundup covers notable class action decisions from federal appellate courts and notable Supreme Court class action cert petitions....more

Shook, Hardy & Bacon L.L.P.

Class Action Decisions Published August 2024 - Developments in Class Action Law

Standing. The D.C. Circuit held that plaintiffs do not have Article III standing to appeal an adverse class certification decision after those individual plaintiffs prevail in their individual suit....more

Mintz

District Court Denies Class Cert in TCPA Suit on Ascertainability Grounds

Mintz on

In a win for Defendant IQVIA, Inc., accused of allegedly sending faxes in violation of the Telephone Consumer Protection Act (TCPA), the United States District Court for the Eastern District of Pennsylvania denied Plaintiff...more

Bilzin Sumberg

Barilla's Pasta Under Fire: Class Action Certified Based on Misleading Label Intimating “Italian” Origin

Bilzin Sumberg on

On May 28, 2024, Chief Magistrate Judge Donna M. Ryu, of the United States District Court for the Northern District of California, certified a class of consumers in an action against Barilla Foods....more

Robinson Bradshaw

Disappointments and Silver Linings in North Carolina Class-Action Law

Robinson Bradshaw on

Life has its disappointments. Sometimes, you think you’ve won a free car, but it turns out that you’ve won only a couple of dollars. And sometimes, you think that an appellate court will clarify a thorny issue of class-action...more

Shook, Hardy & Bacon L.L.P.

Class Action Decisions Published January 2024 - Developments in Class Action Law

Highlights from this issue include: Ascertainability. The Fourth Circuit reiterated that it imposes an implicit “ascertainability” requirement pursuant to which a class cannot be certified unless a court can readily identify...more

BCLP

Fourth Circuit Holds Faxes Received Online Not Subject to TCPA

BCLP on

A fax is a fax is a fax… or is it? In a recent ruling in the long-running TCPA junk fax case Career Counseling, Inc. v. AmeriFactors Financial Group, the Fourth Circuit Court of Appeals held that the statute’s prohibition...more

Troutman Pepper Locke

Fourth Circuit Denies Class Certification Based on Lack of Ascertainability Due to Online Fax Services Being Outside TCPA’s...

Troutman Pepper Locke on

In Career Counseling, Inc. v. Amerifactors Financial Group, LLC, the U.S. Court of Appeals for the Fourth Circuit upheld a district court’s decision denying class certification in a Telephone Consumer Protection Act (TCPA)...more

Ballard Spahr LLP

New Jersey Appellate Division Affirms Dismissal of Consumer Fraud Class Action Against Debt Collector under the New Jersey...

Ballard Spahr LLP on

The Superior Court of New Jersey, Appellate Division in Jennifer Woo-Padva v. Midland Funding, LLC, recently affirmed the dismissal of consumer fraud claims brought against a debt collector pursuant to the New Jersey Consumer...more

Skadden, Arps, Slate, Meagher & Flom LLP

The Class Action Chronicle - August 2023

Post-TransUnion, A Closer Examination of Threshold for Article III Standing- Class action trials are rare. The potential magnitude of an adverse verdict, even when improbable, makes the risks of trial unpalatable for...more

Kilpatrick

Recent developments in ascertainability, uninjured class members, and other class action issues in the second quarter of 2023

Kilpatrick on

Several appellate decisions addressed the “implicit” class action requirement of ascertainability during the second quarter of 2023, with the Third, Tenth and D.C. Circuits weighing in. Meanwhile, the Fifth Circuit maintained...more

Shook, Hardy & Bacon L.L.P.

Class Action Decisions Published May 2023

Ascertainability. The Tenth Circuit affirmed it treated ascertainability as a sub-requirement of numerosity, not a standalone criteria. The Tenth Circuit affirmed the denial of certification of a class of college students who...more

McGuireWoods LLP

Fifth Circuit Reverses ADA Class Certification Because the Class is Not Ascertainable

McGuireWoods LLP on

On January 20, 2023, the U.S. Court of Appeals for the Fifth Circuit reversed the district court’s decision to certify a class under Title II of the Americans With Disabilities Act (“ADA”), which prohibits public entities...more

Robinson Bradshaw

Kelly v. RealPage Inc.: The Third Circuit Lowers the “Heightened Standard” for Ascertainability

Robinson Bradshaw on

Rule 23 does not explicitly require that a court be able to determine who the members are before certifying a class. But judges have found implicit in the Rule a requirement that membership in a defined class be...more

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